Carryover of Net Operating Losses and Other Tax Attributes of Corporations: Hearing Before the Subcommittee on Select Revenue Measures of the Committee on Ways and Means, House of Representatives, Ninety-ninth Congress, First Session, May 22, 1985United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures U.S. Government Printing Office, 1985 - 183 pages |
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67th Congress ABA Recommendation acquiring corporation Aetna allowed American Bar American Law Institute amount apply bankruptcy Bercy business assets buyer capital loss carryback cash Chairman RANGEL change in control change in ownership Congress court credit carryovers creditors debt deductions earnings economic effect enacted equity fair market value FSLIC institutions interest Internal Revenue Code investment assets involving legislative loss and credit loss company loss corporation loss corporation's net operating loss neutrality principle nontaxable offset operating corporation operating loss carryovers outstanding stock owners percentage post-change taxable pre-change present law problems profits proposal provisions purchase price rate of return refundability rehabilitation result Revenue Act section 269 section 382 shareholders shell corporation staff statute statutory stock ownership Subcommittee subsection supervisory mergers survive target corporation tax attributes tax benefits tax law TAX NOTES Tax Section tax-free reorganization taxable income Taxation taxpayer thrift tion trafficking transactions transfer Treasury Type F reorganization utilization
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Page 102 - In determining the meaning of the Revised Statutes, or of any act or resolution of Congress passed subsequent to February twenty-fifth, eighteen hundred and seventy-one, words importing the singular number may extend and be applied to several persons or things; words importing the plural number may include the singular; words importing the masculine gender may be applied to females ; the words "insane person
Page 76 - reorganization" means (A) a merger or consolidation (Including the acquisition by one corporation of at least a majority of the voting stock and at least n majority of the total number of shares of all other classes of stock of another corporation, or substantially all the properties of another corporation...
Page 103 - In the case at bar, the new corporation is essentially different from the old. A corporation organized under the laws of Delaware does not have the same rights and powers as one organized under the laws of New Jersey. Because of these inherent differences in rights and powers, both the preferred and the common stock of the old corporation is an essentially different thing from stock of the same general kind in the new.
Page 57 - Have you made any gifts, other than ordinary and usual presents to family members and charitable donations, during the year immediately preceding the filing of the original petition herein? (If so, give names and addresses of donees and dates, description, and value of gifts.) b.
Page 57 - ... during the year immediately preceding the filing of the original petition herein? (Give a description of the property, the date of the transfer or disposition, to whom transferred or how disposed of, and, if the transferee is a relative or insider, the relationship, the consideration, if any, received therefor, and the disposition of such consideration.) 13.
Page 6 - I am glad to appear before you today to present the views of the Treasury Department in support of HR 8729.
Page 171 - ... (II) a decrease in the amount of such stock outstanding or the amount of stock outstanding of another corporation owning stock in such corporation, except a decrease resulting from a redemption to pay death taxes to which section 303 applies...
Page 57 - Have you made any assignment of your property for the benefit of your creditors, or any general settlement with your creditors, within the two years immediately preceding the filing of the original petition herein?
Page 55 - Where did you file your last federal and state income tax returns for the 2 years immediately preceding the filing of the original petition herein? b. What tax refunds (income and other) have you received during the year immediately preceding the filing of the original petition herein? c. To what tax refunds (income or other), if any, are you, or may you be, entitled?
Page 54 - In whose possession are the records of the two inventories above referred to? (Give names and addresses.) 5. Income other than from operation of business. What amount of income, other than from operation of your business, have you received during each of the two years immediately preceding the filing of the original petition herein?