Taxation of exchange (SWAP) fund capital gains: hearing before the Committee on Ways and Means, House of Representatives, Ninety-fourth Congress, second session, on H.R. 11920 ... March 20, 1976U.S. Government Printing Office, 1976 - 156 lappuses |
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1966 amendment acquired company amendment to section apply appreciated securities bill capital gains tax capital loss Chairman clients Cohen Congress cookies CORMAN counsel depositors deposits effective date enacted Exchange Commission existing law expenses February 17 Federal Street Fund filed FRENZEL Fund of America Fund's Goldman Sachs GOLDSTEIN grandfather clause Income Fund income tax Internal Revenue Code Internal Revenue Service investors IRS ruling issued legislation limited partner limited partnership loophole merge mergers MIKVA million mutual funds pany partnership exchange fund partnership form partnership interest partnership swap funds percent period personal holding company portfolio prior to February problem prospectus provisions registration statement regulated investment companies reliance request for ruling retroactive ruling request Sanders Exchange Fund Sanders ruling section 351 Securities and Exchange shareholders shares solicitation STARK substantial tax consequences tax law tax ruling tax-free diversification taxable taxpayers Thank tion transactions Treasury Vance Sanders VANDER VEEN
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75. lappuse - No gain or loss shall be recognized to a partnership or to any of Its partners In the case of a contribution of property to the partnership In exchange for an Interest in the partnership.
71. lappuse - ... necessary or appropriate in the public interest and consistent with the protection of investors and the purposes fairly intended by the policy and provisions of this title.
33. lappuse - ... (ii) other securities for purposes of this calculation limited, except and to the extent provided in subsection (e), in respect of any one issuer to an amount not greater in value than 5 percent of the value of the total assets of the...
106. lappuse - For purposes of this subtitle, the term "regulated investment company" means any domestic corporation (other than a personal holding company as defined in section 542...
34. lappuse - The transfer results, directly or indirectly, in diversification of the transferors' interests, and (ii) The transferee is (a) a regulated investment company, (b) a real estate investment trust, or (c) a corporation more than 80 percent of the value of whose assets (excluding cash and nonconvertible debt obligations from consideration) are held for investment and are readily marketable stocks or securities, or interests in regulated investment companies or real estate investment trusts.
3. lappuse - The requests should be submitted to John M. Martin, Jr., Chief Counsel, Committee on Ways and Means, 1102 Longworth House Office Building, Washington, DC 20515.
43. lappuse - ... the filing of a registration statement with the Securities and Exchange Commission.
151. lappuse - ... (3) less than 30 percent of its gross income is derived from the sale or other disposition of stock or securities held for less than 3 months...
33. lappuse - ... limited in respect of any one issuer to an amount not greater in value than 5 percent of the value of the total assets of the trust and to not more than 10 percent of the outstanding voting securities of such issuer.
51. lappuse - partnership" includes a syndicate, group, pool, joint venture, or other unincorporated organization through or by means of which any business, financial operation, or venture is carried on, and which is not a corporation or a trust or estate within the meaning of the Code. The term "partnership" is broader in scope than the common law meaning of partnership, and may include groups not commonly called partnerships.