Advisory Group Recommendations on Subchapters C, J, and K of the Internal Revenue Code: Hearings Before the Committee on Ways and Means, House of Representatives, Eighty-sixth Congress, First Session ...
U.S. Government Printing Office, 1959 - Corporations - 1044 pages
Reviews proposed amendments to Internal Revenue Code regarding Subchapters C, corporation distribution of profits; J, estates, trusts, beneficiaries and decedents; and K, partnerships. a. "Revised Report on Partners and Partnerships," Advisory Group on Subchapter K of the Internal Revenue Code of 1954, Dec. 31, 1957 (p. 115-173). b. "Final Report on Estates, Trusts, Beneficiaries, and Decedents," Advisory on Subchapter J of the Internal Revenue Code of 1954, Dec. 30, 1958 (p. 257-359). c. "Revised Report on Corporate Distributions and Adjustments," Advisory Group on Subchapter C of the Internal Revenue Code of 1954, Dec. 11, 1958 (p. 473-603). Includes the following Committee Prints.
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accumulated acquired addition adjusted adopted advisory group allocated allowed amendment amount apply appreciation assets attribution avoidance basis believe beneficiaries capital capital gain CASNER CHAIRMAN charitable collapsible committee complete consideration considered contribution corporation corpus created dealing death decedent deduction definition determining distribution dividend effect election example exception exchange existing law extent fact further gain give hands included individual interest inventory limited liquidation loss means operation ordinary income ownership paid paragraph partner partnership payment percent period permit person possible present law problem proposed provision question reason received recognized recommendation redemption reference regulations relating reorganization respect result revised rule section 306 separate share shareholder situation specific statute statutory subchapter subsection substantial suggested taxable taxpayer tion transaction transfer treated treatment trust WILLIs
Page 585 - ... (B) Stock of the distributing corporation possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvotIng stock which is limited and preferred as to dividends...
Page 622 - ... 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 597 - In the case of an exchange to which section 355 (or so much of section 356 as relates to section 355) applies.
Page 481 - Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed In terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1954.
Page 593 - ... it is established to the satisfaction of the Secretary or his delegate that the retention by the distributing corporation of stock (or stock and securities) in the controlled corporation was not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income tax...
Page 327 - The amount of all items of gross income in respect of a decedent which are not properly includible in respect of the taxable period in which falls the date of his death...
Page 275 - The taxable income of an estate or trust shall be computed in the same manner as in the case of an individual, except as otherwise provided in this part. The tax shall be computed on such taxable income and shall be paid by the fiduciary.
Page 317 - For purposes of this subpart, the term "adverse party" means any person having a substantial beneficial interest in the trust which would be adversely affected by the exercise or nonexercise of the power which he possesses respecting the trust.
Page 531 - The common parent corporation owns directly stock possessing at least 80 percent of the voting power of all classes of stock and at least 80 percent of each class of the nonvoting stock of at least one of the other Includlble corporations. As used in this subsection, the term "stock" does not include nonvoting stock which is limited and preferred as to dividends. (3) The term "affiliated group...
Page 321 - The grantor shall be treated as the owner of any portion of a trust, whether or not he Is treated as such owner under section 674, whose Income without the approval or consent of any adverse party Is, or. In the discretion of the grantor or a nonadverse party, or both, may be — (1) Distributed to the grantor; (2) Held or accumulated for future distribution to the grantor...