Statement of the Change Made in the Revenue Act of 1921 by H.R. 6715. Mar. 6, 19241924 - 38 pages |
Common terms and phrases
12 per cent applied assessment and collection assets bill corresponds Board of Tax capital gain capital losses capital net gain changes commissioner corresponds to paragraph corresponds to section corresponds to subdivision deficiency distraint distribution of earnings dividend earned income earnings and profits erty estate tax exempt from tax existing law provides extension filing gain or loss grantor gross income income tax law is repealed law which corresponds Liberty bond limitation loss is recognized nonresident alien old corporation omitted ordinary income ordinary net income paid payment period preferred stock present law prior to March proceeding in court profits accumulated prior provisions of section purpose of determining result return of capital revenue act Revised Statutes section 203 sentence of section share of stock similar provision sold stock of corporation stockholders subdivision d subdivision provides subsequent sale Tax Appeals tax imposed taxable gain taxpayer tion trade or business transaction transfer X company
Popular passages
Page 9 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Page 21 - P) if such corporation, however created or organized, is formed or availed of for the purpose of preventing the imposition of the surtax upon its shareholders or the shareholders of any other corporation, through the medium of permitting earnings or profits to accumulate instead of being divided or distributed...
Page 18 - capital assets" as used in this section means property acquired and held by the taxpayer for profit or investment for more than two years (whether or not connected with his trade or business), but does not include property held for the personal use or consumption of the taxpayer or his family, or stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year.
Page 3 - There shall be recognized, and taxed as a dividend, so much of the gain as is not in excess of his ratable share of the earnings and profits of the corporation...
Page 10 - ... the basis of property so acquired is the same as it would be in the hands of the grantor increased in the amount of gain or decreased in the amount of loss recognized to the grantor upon such transfer under the law applicable to the year in which the transfer was made. If the taxpayer acquired the property by a transfer in trust, this basis applies whether the property be in the hands...
Page 15 - The basis for determining the gain or loss from the sale or other disposition of property acquired after February 28, 1913, shall be the cost of such property...
Page 3 - Code to be applied against the basis of the property exceeds such basis. Except as otherwise provided in section...
Page 13 - Section 373(b)(1) sets forth certain conditions under which the basis of property acquired by a railroad corporation is the same as it would have been in the hands of the railroad corporation whose property was acquired.
Page 2 - The Report of the House Ways and Means Committee (Report No. 179, 68th Cong., 1st Sess.) states with respect to § 201(c), at page 11: ". . . the Treasury has construed the existing law as taxing liquidating dividends, not as capital gains, but as dividends subject to the surtax rates. The proposed bill, as did the 1918 act, treats a liquidating dividend as a sale of the stock to the corporation and recognizes the true effect of such a distribution.
Page 10 - USCA § 935(a)(8), and it is there expressly provided that the basis for determining the gain or loss from the sale or other disposition of property acquired after December 31, 1920, shall be the same as it would be in the hands of the transferor...