Internal Revenue Bulletin: Cumulative bulletin, Part 1, Volume 2
U.S. Government Printing Office, 1964
A consolidation of all items of a permanent nature published in the weekly Internal revenue bulletin, ISSN 0020-5761, as well as a cumulative list of announcements relating to decisions of the Tax Court.
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acquired added additional adjusted allowed amended amount apply attributable averaging basis bill billion capital capital gain changes charitable committee computation considered contract contributions corporation cost December 31 deduction defined depreciation described determined distribution dividends domestic earnings effect election employee ending example exceed excess exchange excluded exemption exercise existing expenses extent filing foreign gain granted gross income held holding company income House imposed included income tax increase individual interest investment January less limitation liquidation loss means mineral months operating option paid paragraph parent payments percent period personal holding company present law provides purchase qualified reason received referred regulations relating residence respect result rule Senate separate share shareholders stock option subparagraph subsection subsidiary taken taxable taxable income taxable years beginning taxpayer term tion transfer treated treatment United
Page 50 - Stock owned, directly or indirectly, by or for a corporation, partnership, estate, or trust shall be considered as being owned proportionately by its shareholders, partners, or beneficiaries. (2) Family and partnership ownership. An individual shall be considered as owning the stock owned, directly or indirectly, by or for his family or by or for his partner.
Page 80 - ... more than 50 percent of the total combined voting power of all classes of stock entitled to vote or more than 50 percent of the total value of shares of all classes of stock of each corporation, taking into account the stock ownership of each such person only to the extent such stock ownership is identical with respect to each such corporation.
Page 72 - ... is subject to the jurisdiction of the Interstate Commerce Commission under Part III of the Interstate Commerce Act or subject to the jurisdiction of the Federal Maritime Board under the Intercoastal Shipping Act, 1933...
Page 231 - In the hands of the transferor corporation, and the principal purpose for which such acquisition was made Is evasion or avoidance of Federal Income tax by securing the benefit of a deduction, credit, or other allowance which such person or corporation would not otherwise enjoy, then such deduction, credit, or other allowance shall not be allowed.
Page 47 - ... or more in value of the outstanding stock of the corporation is owned, directly or indirectly, by or for an individual entitled to the use of the property; whether such right is obtained directly from the corporation or by means of a sublease or other arrangement.
Page 48 - If at some tune during the taxable year 25 percent or more in value of the outstanding stock of the corporation is owned, directly or Indirectly, by or for the individual who has performed, is to perform, or may be designated (by name or by description) ęs the one to perform, such services.
Page 36 - For purposes of this part, the term "restricted stock option" means an option granted after February 26, 1945, and before January 1, 1964 (or, if It meets the requirements of subsection (c) (3) , an option granted after December 31, 1963), to an Individual, for any reason connected with his employment by a corporation, If granted by the employer corporation or Its parent or subsidiary corporation, to purchase stock of any of such corporations, but only if...
Page 31 - ... at the time of such payment unless such payment is made to an employee of the trust as remuneration for services rendered as such employee and not as a beneficiary of the trust, or (B) under or to an annuity plan which, at the time of such payment, meets the requirements of section 401 (a) (3), (4), (5), and (6...
Page 326 - At any time during the taxable year more than 50 percent in value of its outstanding stock is owned, directly or indirectly, by or for not more than five individuals who are citizens or residents of the United States, hereinafter called "United States group".