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 acquisition value 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 THE LIBRARY court credit carryovers creditors debt deductions earnings economic effect enacted equity fair market value Federal FSLIC institutions interest Internal Revenue Internal Revenue Code investment assets involving legislative LIBRARY OF CONGRESS loss and credit loss company loss corporation loss corporation's net operating loss neutrality principle nontaxable offset operating corporation operating loss carryovers owners percentage pre-change present law problems profits proposal provisions purchase price rate of return refundability rehabilitation result Revenue Act section 269 shareholders shell corporation statute statutory stock ownership Subcommittee subsection supervisory mergers survive target corporation tax attributes tax benefits tax law Tax Section 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 171 - ... (B) the increase in percentage points at the end of such taxable year is attributable to — (i) a purchase by such person or persons of such stock, the stock of another corporation owning stock in such corporation, or an interest in a partnership or trust owning stock in such corporation...
Page 54 - Have you assigned any of your accounts receivable during the year immediately preceding the filing of the original petition herein?
Page 52 - By whom have your books of account and records been audited during the two years immediately preceding the filing of the original petition herein? (Give names, addresses, and dates of audits.) c. In whose possession are your books of account and records?
Page 58 - What repayments of loans have you made during the year immediately preceding the filing of the original petition herein...
Page 4 - I am glad to appear before you today to present the views of the Treasury Department in support of HR 8729.
Page 58 - ... c. Have you, either during the year immediately preceding or since the filing of the original petition herein, agreed to pay any money or transfer any property to an attorney at law, or to any other person on his behalf?
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 58 - What bank accounts have you maintained, alone or together with any other person, and in your own or any other name, within the two years immediately preceding the filing of the original petition herein? (Give the name and address of each...