Lapas attēli
PDF
ePub

8.

III. General Explanation of the Act-Continued

I.

Tax Treatment of Foreign Income-Continued

6.

5. Amendments to the Foreign Tax Credit (Secs. 1031-1037). -
Exclusion From Gross Income and From Gross Estate of
Portfolio Investments in the United States of Non-
resident Aliens and Foreign Corporations (Sec. 1041).
7. Changes in Ruling Requirements Under Section 367 and
Changes in Amounts Treated as Dividends (Sec. 1042)___
Contiguous Country Branches of Domestic Insurance
Companies (Sec. 1043) ___

Page

233

255

256

267

9.

Transitional Rule for Bond, Etc., Losses of Foreign Banks
(Sec. 1044).

271

10.

11.

12.

Tax Treatment of Corporations Conducting Trade or
Business in Possessions of the United States (Sec. 1051)__
Western Hemisphere Trade Corporations (Sec. 1052) -
China Trade Act Corporations (Sec. 1053)-

13. Denial of Certain Tax Benefits for Cooperation With or
Participation in an International Boycott (Secs. 1061-
1064, 1066 and 1067)__

272

278

280

282

14. Denial of Certain Tax Benefits Attributable to Bribe-
Produced Income (Sec. 1065) ----

288

J.

K.

Domestic International Sales Corporations (Sec. 1101).
Administrative Provisions....

290

301

1. Public Inspection of Written Determinations by Internal
Revenue Service (Sec. 1201) – –

301

2.

Disclosure of Tax Returns and Tax Return Information
(Sec. 1202)

[blocks in formation]

Assessments in Case of Mathematical or Clerical Errors
(Sec. 1206)--

371

7. Withholding Tax Provisions__

375

a. Withholding of State and District Income Taxes
for Military Personnel (Sec. 1207(a))_

375

e.

b. Withholding State and City Income Taxes From
the Compensation of Members of the National
Guard or the Ready Reserve (Sec. 1207(b)) _
Voluntary Withholding of State Income Taxes
From the Compensation of Federal Employees
(Sec. 1207 (c)) –

C.

d. Withholding Tax on Certain Gambling Winnings
(Sec. 1207 (d)) _ _

Withholding of Federal Taxes on Certain Indi-
viduals Engaged in Fishing (Sec. 1207 (e))

[ocr errors][merged small][merged small][merged small][merged small]

8.

State-Conducted Lotteries (Sec. 1208)

383

9.

Minimum Exemption from Levy for Wages, Salary, and
Other Income (Sec. 1209) -

[blocks in formation]

Interest on Mathematical Errors on Returns Prepared by
IRS (Sec. 1212).

388

L. Tax-Exempt Organizations.

390

1.

2.

Modification of Transitional Rule for Sales of Property
by Private Foundations (Sec. 1301).
New Private Foundation Set-Asides (Sec. 1302).

390

391

3.

Reduction in Minimum Distribution Amount for Private
Foundations (Sec. 1303)

394

4.

Extension of Time To Conform Charitable Remainder
Trusts for Estate Tax Purposes (Sec. 1304) -

396

5.

Income From Fairs, Expositions, and Trade Shows (Sec.
1305)__

398

6. Declaratory Judgments as to Tax-Exempt Status as
Charitable, etc., Organization (Sec. 1306) .

400

7. Lobbying Activities of Public Charities (Sec. 1307) -

407

L.

8.

9.

III. General Explanation of the Act-Continued
Tax-Exempt Organizations-Continued

Tax Liens, etc., Not to Constitute "Acquisition Indebted-
ness" (Sec. 1308)__.

Extension of private foundation transition rule for sale
of business holdings (Sec. 1309) __

Page

416

418

10.
11.

Private foundations imputed interest (Sec. 1310).
Unrelated Business Income from Services Provided by a
Tax-exempt Hospital to Other Tax-exempt Hospitals
(Sec. 1311).

420

421

12.

Clinical Services Provided to Tax-Exempt Hospitals (Sec.
1312).

422

13. Exemption of Certain Amateur Athletic Organizations
From Tax (Sec. 1313)

M. Capital Gains and Losses _

423

425

1.

Deduction of Capital Losses Against Ordinary Income
(Sec. 1401) -.

425

2.

Increase in Holding Period for Long-Term Capital Gains
(Sec. 1402). -

426

3. Capital Loss Carryover for Regulated Investment Com-
panies (Sec. 1403)

427

4. Gain on Sale of Residence by Elderly (Sec. 1404). N. Pension and Insurance Taxation..

428

430

1. Individual Retirement Account (IRA) for Spouse (Sec.
1501)

430

2.

Limitation on Contributions to Certain H.R. 10 Plans
(Sec. 1502).

431

3.

Retirement Deductions for Members of Armed Forces
Reserves, National Guard and Volunteer Firefighters
(Sec. 1503)

432

4. Tax-Exempt Annuity Contracts in Closed-End Mutual
Funds (Sec. 1504) -

433

5.

Pension Fund Investments in Segregated Asset Accounts
of Life Insurance Companies (Sec. 1505)

[merged small][ocr errors][merged small]

6. Study of Salary Reduction Pension Plans (Sec. 1506).
Consolidated Returns for Life and Mutual Insurance
Companies (Sec. 1507)_.

434

435

8.

Guaranteed Renewable Life Insurance Contracts (Sec.
1508).

438

9. Study of Expanded Participation in Individual Retirement
Accounts (Sec. 1509) -

439

10.

Taxable Status of Pension Benefit Guaranty Corporation
(Sec. 1510)

440

11.

Level Premium Plans Covering Owner-Employees (Sec.
1511)

440

0.

1.

2.

333

1604)__

P.

12. Lump-Sum Distributions From Pension Plans (Sec. 1512).
Real Estate Investment Trusts.

Deficiency Dividend Procedure (Sec. 1601)__.
Distributions of REIT Taxable Income After Close of
Taxable Year (Secs. 1604 and 1605) -

3. Property Held for Sale (Sec. 1603).

4. Failure to Meet Income Source Tests (Sec. 1602) –

5. Other Changes in Limitation and Requirements (Sec.

Railroad and Airline Provisions.

[ocr errors][merged small][merged small][merged small][merged small][merged small][merged small][merged small][merged small]

1.

Treatment of Certain Railroad Ties (Sec. 1701(a)).

460

2. Limitation on Use of Investment Tax Credit for Railroad
Property (Sec. 1701(b)) _ _.

461

3.

Amortization of Railroad Grading and Tunnel Bores
(Sec. 1702)---

463

4. Limitation on Use of Investment Tax Credit for Airline
Property (Sec. 1703)__

[blocks in formation]

United States International Trade Commission (Sec. 1801)_
Trade Act of 1974 Amendments (Sec. 1802).

468

469

R.

"Deadwood" Provisions.

470

[blocks in formation]

1.

Unified Rate Schedule for Estate and Gift Taxes; Unified
Credit in Lieu of Specific Exemptions (Sec. 2001).
2. Increase in Limitations on Marital Deductions; Fractional
Interest of Spouse (Sec. 2002)_

3. Valuation for Purposes of the Federal Estate Tax of Certain
Real Property Devoted to Farming or Closely Held
Business Use (Sec. 2003)___

Page

525

525

532

536

[blocks in formation]

Extension of Time for Payment of Estate Tax (Sec. 2004). 5. Carryover Basis (Sec. 2005).

6.

543

551

564

583

584

588

598

3.

Tax Treatment of Certain Housing Associations (Sec. 2101).
Treatment of Certain Crop Disaster Payments (Sec. 2102) --
Tax Treatment in the Case of Certain 1972 Disaster Loans
(Sec. 2103) -

598

604

605

4.

5.

7.

Tax Treatment of Certain Debts Owed by Political Parties
to Accrual Basis Taxpayers (Sec. 2104) _ _
Tax-Exempt Bonds for Student Loans (Sec. 2105).
6. Personal Holding Company Amendments (Sec. 2106) -
Work Incentive (WIN) and Federal Welfare Recipient
Employment Incentive Tax Credits (Sec. 2107)__

607

608

610

613

9.

8. Excise Tax on Parts for Light-Duty Trucks (Sec. 2108).
Exclusion From Manufacturers' Excise Tax for Certain
Articles Resold After Modification (Sec. 2109) –

10. Franchise Transfers (Sec. 2110).

614

615

616

11. Employer's Duties to Keep Records and to Report Tips
(Sec. 2111).-

617

12.

Treatment of Certain Pollution Control Facilities (Sec.
2112)____

619

13.

Clarification of Status of Certain Fishermen's Organiza-
tions (Sec. 2113).

621

14.

Innocent Spouse (Sec. 2114).

622

15.

Rules Relating to Limitations on Percentage Depletion in
Case of Oil and Gas Wells (Sec. 2115) -

624

16. Federal Collection of State Individual Income Taxes (Sec.
2116)__

628

17.

Cancellation of Certain Student Loans (Sec. 2117)

630

20.

18. Simultaneous Liquidation of Parent and Subsidiary
Corporations (Sec. 2118)..

19. Prepublication Expenses (Sec. 2119)..

Contributions to Capital of Regulated Public Utilities in
Aid of Construction (Sec. 2120)__

631

633

635

21.

Prohibition of Discriminatory State Taxes on Production
and Consumption of Electricity (Sec. 2121).

638

22.

Deduction for Cost of Removing Architectural and
Transportation Barriers for Handicapped and Elderly
Persons (Sec. 2122) -

639

23.

24.

Reports on High-Income Taxpayers (Sec. 2123).
Tax Treatment of Certified Historic Structures (Sec. 2124)_
25. Supplemental Security Income for Victims of Certain
Natural Disasters (Sec. 2125)__.

640

643

645

26. Net Operating Loss Carryovers for Cuban Expropriation
Losses (Sec. 2126)..

[blocks in formation]

Treatment of Gain from Sales or Exchanges Between
Related Parties (Sec. 2129).

651

31.

30. Application of Section 117 to Certain Education Programs
for Members of the Uniformed Services (Sec. 2130) -
Exchange Funds (Sec. 2131)---

654

655

[blocks in formation]

32.

33.

34.

35.

Contributions of Certain Government Publications (Sec.
2132).

Page

667

667

668

Study of Tax Incentives by Joint Committee (Sec. 2133)
Prepaid Legal Services (Sec. 2134).

Certain Charitable Contributions of Inventory (Sec. 2135)_
36. Tax Treatment of Grantor of Certain Options (Sec. 2136)_
37. Exempt-Interest Dividends of Regulated Investment

672

673

Companies (Sec. 2137)__

678

38. Common Trust Fund Treatment of Certain Custodial
Accounts (Sec. 2138) ---

679

39. Support Test for Dependent Children of Separated or
Divorced Parents (Sec. 2139) _.

680

40.

Deferral of Gain on Involuntary Conversion of Real
Property (Sec. 2140) ----

681

41. Livestock Sold on Account of Drought (Sec. 2141)

681

i. SUMMARY AND REASONS FOR THE ACT

The Tax Reform Act of 1976 will serve six major purposes. First, it will improve the equity of the tax system at all income levels without impairing economic efficiency and growth. Second, the Act effects important simplifications of the tax system by modifying certain deductions and credits affecting individuals, by increasing the standard deduction to encourage taxpayers to switch from itemizing their deductions to using the standard deduction, and by redrafting complex provisions of the tax law and deleting obsolete and little used provisions. Third, the Act extends the fiscal stimulus provided by the Tax Reduction Act of 1975 and extended by the Revenue Adjustment Act of 1975, and makes permanent part of these tax cuts for individuals. Fourth, the Act encourages capital formation by extending the increased investment credit for four years, by modifying the application of the credit, by extending and revising the incentive for investing in employee stock ownership plans, and by liberalizing the net operating loss carryover. Fifth, it improves the administration of the tax laws by making it more efficient and strengthening taxpayers' rights. Sixth, the Act makes a major revision in the estate and gift taxes. It reduces the estate and gift tax for small- and medium-sized estates and at the same time eliminates tax avoidance possibilities.

In addition, the Act makes certain changes in the operation of the U.S. International Trade Commission as well as the withholding of preferential trade treatment for countries who aid or abet international terrorists.

(1)

« iepriekšējāTurpināt »