Imputed Interest: Hearing Before the Subcommittee on Taxation and Debt Management of the Committee on Finance, United States Senate, Ninety-ninth Congress, First Session, on S. 56; S. 71; S. 217; S. 251; S. 729; and H.R. 2475, May 20, 1985
U.S. Government Printing Office, 1985 - Income tax - 309 pages
What people are saying - Write a review
We haven't found any reviews in the usual places.
Other editions - View all
$2 million 80 percent abusive accounting accrual addition allow amount applicable Federal rate appropriate assumed assumptions basis believe below-market bill borrower building buyer capital cash Chairman changes charge clubs Code Committee communities complex concern Congress continuing cost deal debt debt instrument deductions deferred depreciation determined discount economic effect example exemption existing fact fees gain going Government higher House imputed interest rules income increase interest income interest rates Internal Revenue Code investment involving issue legislation lender less limited loans lower maturity Means method mortgage obligations OID rules original paid parties payments period potential present principal problem proposed purchase real estate real property reasonable residence result revenue seller financing Senator Chafee statement taxpayers term test rate transactions Treasury
Page 15 - However, if property used in a trade or business or held for the production of income...
Page 117 - If any amount based on a fixed rate of simple or compound interest is actually payable or will be treated as constructively received under section 451 and...
Page 13 - ... 483 and 1274 if either (1) at the time of the sale, the property was the seller's (or if applicable, the decedent's) principal residence (within the meaning of sec. 1034) or (2) during the two-year period prior to the sale, no substantial portion of the property was of a character subject to an allowance for depreciation. Thus, an assumption of a loan in connection with the sale of a principal residence, or of a vacation home on which a taxpayer may not claim depreciation (eg, by reason of sec....
Page 13 - ... in the case of varying rates of interest, put or call options, indefinite maturities, contingent payments, assumptions of debt instruments, conversion rights, or other circumstances...
Page 10 - A potentially abusive situation includes any transaction involving a "tax shelter" as defined in section 6661(bX2XC). It may also include any other situation which because of (1) recent sales transactions, (2) nonrecourse financing, (3) financing with a term beyond the economic life of the property, or (4) other circumstances, is of a type which the Secretary of the Treasury by regulations identifies as having a potential for abuse.
Page 8 - ... property if (1) neither the instrument nor the property received in exchange for the instrument is publicly traded; (2) some or all of the payments under the instrument are due more than six months after the sale; and (3) the stated redemption price at maturity of the instrument exceeds its stated principal amount (if there is adequate stated interest) or its "imputed principal amount" (if there is inadequate stated interest).
Page 11 - In determining a lease term— (i) there shall be taken into account options to renew, and (ii) 2 or more successive leases which are part of the same transaction (or a series of related transactions) with respect to the same or substantially similar property shall be treated as 1 lease.
Page 194 - General Explanation of the Revenue Provisions of the Deficit Reduction Act of 1984, prepared by the Staff of the Joint Committee on Taxation.