Background on Tax Shelters: Scheduled for a Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance, on June 24, 1983
U.S. Government Printing Office, 1983 - Tax shelters - 37 pages
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accrual-basis accrued accumulated earnings allocation of partnership amortized amount borrowed apply at-risk rules attributable to nonrecourse basis cash method charitable contribution Commissioner computed convert ordinary income current deduction deferred payments deﬁned depreciation discount bonds dividend economic accrual ERTA exchange expenses fair market value ﬁnance ﬁrst foreign corporation gems income tax income to tax-favored indebtedness interest deductions Internal Revenue Internal Revenue Service investors lease lessor limited long-term capital gain ment mutual fund noncorporate nonrecourse debt nonrecourse liability nonrecourse loans obligations issued original issue discount paid partner partnership income partnership interests penalty percent present law present value purchase price real property recapture reﬂect section 483 seller shareholders short sale sports franchise straddle syndicate tax beneﬁts tax liability Tax Reform Act tax shelter investment tax-favored income tax-shelter investments taxable TEFRA tion transactions treated treatment U.S. tax valuation value of money yield to maturity