High-income Taxpayers and Related Partnership Tax Issues: Hearing Before the Subcommittee on Oversight of the Committee on Ways and Means, House of Representatives, Ninety-ninth Congress, First Session, September 20, 1985

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153. lappuse - Totalling up taxes and rebates for the full four years, we found that fifty of the 275 companies paid an overall total of nothing or less in federal income taxes over the entire 1981-84 period. Despite $56.8 billion in pretax domestic profits, these 50 companies received net tax rebates totalling $2.4 billion. As a group, the 275 companies paid an overall four-year effective tax rate of only 15 percent, less than one-third of the 46 percent tax rate that the tax code purportedly requires major corporations...
2. lappuse - ... with respect to its so-called "clearance letters." In addition, we suggested to the IRS more than three years ago that the procedures of the Federal Reserve Board in complying with the Freedom of Information Act also provided a helpful pattern for consideration by the IRS. Similarly, the Office of the Assistant Secretary for Tax Policy in the Department of the Treasury has established a helpful set of Information Act compliance procedures, as a result of a suit by Tax Analysts and Advocates....
94. lappuse - Agreement or any other agreement* or documents referred to herein are not complete, and each such statement is deemed to be qualified and amplified in all respects by the provisions of such agreements and documents, copies of which, if not attached hereto, are or will be available for examination at the office of the Partnership located at 25 East 26th Street, New York, New York 10010.
1. lappuse - Chairman PICKLE. The Chair will ask the committee to come to order again and ask Mr.
155. lappuse - ... again, you are being told that America's international competitive position hangs in the balance, with loopholes the key to our ability to compete with foreign goods. Such claims are incredible in and of themselves, but they are especially ironic in light of the current economic situation. In 1981, the business lobbying groups were given virtually everything they had ever dreamed of in terms of tax loopholes. Yet, since then, we have seen one of the weakest performances in plant and equipment...
1. lappuse - Committee on Ways and Means, US House of Representatives today announced a hearing on...
44. lappuse - Nearly half of the high income taxpayers in 1983 paid a substantial share of their income in taxes — 47 percent paid taxes of at least 20 percent of their positive income. These high-income taxpayers made hardly any more use of special provisions of the tax code for reducing tax liability than did typical upper-middle-income returns. Table 4 Limited Partnerships and Publicly offered Tax Shelters...
7. lappuse - If you look at the data, you will see that of the 67 percent, 36.2 percent of those losses were partnership losses. It is this kind of data that suggests to us that it is appropriate to examine what it is about those partnership losses that contribute to the use of partnerships by high-income taxpayers. High-income taxpayers as a group, including those paying significant taxes, also make substantial use of above-the-line offsets, but less than the high-income taxpayers with low total tax liability....
51. lappuse - Section 1231 losses and foreign source income reported on the Schedule K. Note that income from other partnerships is excluded from the aggregate amount and from the partnership income reported for each industry (with the exception of partnerships characterized as "holding companies*) . The deductions shown in the third column of Table 2 include salaries and wages, rent, taxes, bad debts, repairs, rental expenses (other than interest and depreciation) , and other deductions shown on the Form 1065.
128. lappuse - Department feel compelled to develop yet another measurement of income when four different measurements in 3/ another measurement of income when four different measurements in use for a number of years are readily available? II. TAXES PAID BY HIGH INCOME TAXPAYERS The Report grossly overstates the percentage of high income taxpayers who paid little or no tax. This is due primarily to the inflated TPI standard discussed earlier. The fact is that the overwhelming majority of high income taxpayers pay...

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