Tax Treatment of Thrift Partnership: Joint Hearing Before the Subcommittee on Taxation and Debt Management of the Committee on Finance and the Subcommittee on Housing and Urban Affairs of the Committee on Banking, Housing, and Urban Affairs, United States Senate, Ninety-seventh Congress, Second Session, on S. 1828, February 5, 1982U.S. Government Printing Office, 1982 - 152 pages |
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all-American mortgage amend analysis assumed assumptions average Bank Board basis points bill book value Bowery Savings Bank building and loan capital account Chairman Code Committee contributed mortgages contributed property Coopers & Lybrand cost current market deduction discount rate earnings estimate funds gain or loss impacts of thrift increase interest rates investor partners legislation loan association low-yield mortgages McKEE MCKINNEY mortgage market municipal bonds net worth original capital contribution partnership agreement partnership income partnership operations partnership participation Partnership Tax Act payments present value problem projected qualified thrift institution qualified thrift partnership rate of return reinvest residential mortgage loans REVENUES TO TREASURY rules savings and loan Senator PACKWOOD substantial economic effect tax effect tax losses tax revenue tax shelters tax system tax treatment taxable income taxpayer thrift institution participants thrift partners Thrift Partnership Tax tions Treasury Department Treasury revenues Urban Affairs worth yield
Popular passages
Page 141 - For the purpose of this rule a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers ; that is, one who as a merchant buys securities and sells them to customers with a view to the gains and profits that may be derived therefrom.
Page 145 - Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 146 - The purpose of section 482 is to place a controlled taxpayer on a tax parity with an uncontrolled taxpayer...
Page 9 - The character of any item of income, gain, loss, deduction, or credit included in a partner's distributive share under paragraphs (1) through (8) of subsection (a) shall be determined as if such item were realized directly from the source from which realized by the partnership, or incurred in the same manner as incurred by the partnership.
Page 141 - Taxpayers who buy and sell or hold securities for investment or speculation, irrespective of whether such buying or selling constitutes the carrying on of a trade or business, and officers of corporations and members of partnerships who in their individual capacities buy and sell securities, are not dealers in securities within the meaning of this section.
Page 54 - I am pleased to have this opportunity to present the views of the Treasury Department on...
Page 9 - Whether the partnership or a partner individually has a business purpose for the allocation; whether the allocation has "substantial economic effect", that is, whether the allocation may actually affect the dollar amount of the partners...
Page 13 - ... the contribution of property to a partnership in exchange for an interest in the partnership.
Page 2 - Some reassurance on the need for such a program is given in the testimony earlier in 1968 before the Subcommittee on Housing and Urban Affairs of the Senate Committee on Banking and Currency by Secretary Robert C.
Page 9 - In this respect, the amount of partnership gross income from which was derived the partner's distributive share of any item of partnership income, gain, loss, deduction, or credit (as included or disclosed in the partner's return) is considered as an amount of gross income stated in the partner's return for the purposes of section 6501 (e).