Description of H.R. 6056 (Technical Corrections Act of 1982): Scheduled for a Hearing Before the Committee on Ways and Means, on April 27, 1982 |
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accumulated deductible employee amendments amount apply bill and sec bill would allow bill would clarify bill would provide clarify the rules Code compensation credit for ESOP Crude Oil decedent deductible employee contributions dependent care assistance determining dividend reinvestment plans donee spouse Economic Recovery Tax elect straight-line eligible ERTA added ERTA extended ERTA increased ERTA provided ESOP contributions estate tax exclusion sec gains gift tax in-house research expenses Incentive stock options income interest individual retirement savings Installment Sales Revision investment credit investment tax credit itemized deductions July 20 limit marital deduction minimum tax ordinary income paid or incurred payments percent period placed in service prior law public utility property QTIP property qualified terminable interest Recovery Tax Act regulated futures contract related parties Sales Revision Act simplified employee pensions subchapter S corporation sum distributions taken into account tax credit ESOP tax-free rollover tax-qualified plan taxpayer tion transfer Treasury windfall profit tax
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Page 16 - For purposes of this section, there is a valuation overstatement if the value of any property, or the adjusted basis of any property, claimed on any return exceeds 150 percent of the amount determined to be the correct amount of such valuation or adjusted basis (as the case may be).
Page 7 - ERTA added provisions to allow all income with respect to certain employee stock options ("incentive stock options") to be taxed at capital gains rates when the stock received on the exercise of the option is sold. The amount of stock with respect to which incentive stock options may be granted in any year after 1980 is limited to $100,000 (determined at the time of grant) plus a partial carryover of any previously unused amount. Explanation of provision The bill clarifies that if the option stock...
Page 8 - ... incentive stock options and that the limit is not affected by nonqualified options. The bill allows a good faith valuation to be used in applying the maximum dollar limit and the carryover of any unused limit, under regulations prescribed by the Treasury. The bill provides that an employee's transfer of stock acquired pursuant to the exercise of a statutory stock option to acquire other stock in connection with the exercise of an incentive stock option will be treated as a recognition transaction...
Page 13 - Act repeals section 6166A and expands the provisions of section 6166 to all estates in which the value of an interest in a closely held business exceeds 35 percent of the value of the adjusted gross estate.
Page 5 - Generally, for real property and low-income housing placed in service or disposed of in a short tax year, the above rule does not apply and the deduction is based on the number of months the property is in service during the year, regardless of the length of the tax year and regardless of the recovery period and method used. Any unrecovered allowance (the difference between the recovery allowance properly allowable for the short tax year and the recovery allowance that would have been allowable if...
Page 12 - ... which it was valued in the decedent's estate, all, or a portion of, the Federal estate tax benefits obtained by virtue of the reduced valuation are recaptured by...
Page 9 - ERTA generally allows individuals an annual deduction for contributions to an individual retirement account, annuity, or bond (IRA) limited to the lesser of $2,000 ($2,250 for a spousal IRA) or 100 percent of compensation. In lieu of the deduction for IRA contributions, an employee is allowed a deduction (subject to the IRA limit) for qualified voluntary employee contributions to an employer's retirement plan. Accumulated deductible employee contributions under an employer's plan generally are subject...
Page 11 - ... regulated public utilities which conform the rules for the payroll-based tax credit for ESOP contributions to the rules for the investment-based tax credit for ESOP contributions. These rules limit the normalization requirements to compensation paid which is subject to ratemaking. The bill clarifies that the tax-qualified status of an ESOP is not affected merely because employer contributions are determined solely by reference to the payroll-based tax credit allowable to the employer for the...
Page 4 - ... determined by multiplying the deduction which would have been allowable if the recovery year were not a short taxable year by a fraction the numerator of which equals the number of months and part-months in the short taxable year and the denominator of which is 12. This paragraph shall not apply to 15-year real property for the year the property is placed in service or disposed of. Proposed Regulations . (2) Subsequent years
Page 7 - ERTA added a 25-percent income tax credit based on the amount by which a taxpayer's qualified research expenditures for the taxable year exceed the average qualified research expenditures in a base period (generally, the preceding three taxable years). Qualified research expenses include "in-house research expenses" and "contract research expenses".