Description of Possible Committee Amendment Proposed By Chairman Rostenkowski to H.R. 4333 (The Technical Corrections Act of 1988) Jcx-11-88
Description of Possible Committee Amendment Proposed By Chairman Rostenkowski to H.R. 4333 (The Technical Corrections Act of 1988) Jcx-11-88
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Mirror subsidiary transactions . — The amendment would modify the transition rule applicable to "mirror subsidiary" and related transactions, to clarify that the ownership of distributees may be aggregated (to the extent permitted by prior law) in the case of certain distributees whose ownership of the distributing corporation was indirect, through an intermediate corporation that goes out of existence in the transaction.
3. Limitation on use of preacquisition losses to offset built-in gains . ...-- a. Ordering rules for losses . — The amendment would clarify the order in which losses are used where losses are subject to limitation (under new section 384) because they may not be used to offset built-in gains.
-41- b. Effective date . — For transactions occurring before March 31, 1988, the amendment would provide that a taxpayer could make an election to apply the limitations on the use of preacquisition losses to offset built-in gains not taking into account the provisions of the technical corrections bill.
What to read after Description of Possible Committee Amendment Proposed By Chairman Rostenkowski to H.R. 4333 (The Technical Corrections Act of 1988) Jcx-11-88?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
To quickly assess the difficulty of the text, read a short excerpt:
Mirror subsidiary transactions . — The amendment would modify the transition rule applicable to "mirror subsidiary" and related transactions, to clarify that the ownership of distributees may be aggregated (to the extent permitted by prior law) in the case of certain distributees whose ownership of the distributing corporation was indirect, through an intermediate corporation that goes out of existence in the transaction.
3. Limitation on use of preacquisition losses to offset built-in gains . ...-- a. Ordering rules for losses . — The amendment would clarify the order in which losses are used where losses are subject to limitation (under new section 384) because they may not be used to offset built-in gains.
-41- b. Effective date . — For transactions occurring before March 31, 1988, the amendment would provide that a taxpayer could make an election to apply the limitations on the use of preacquisition losses to offset built-in gains not taking into account the provisions of the technical corrections bill.
What to read after Description of Possible Committee Amendment Proposed By Chairman Rostenkowski to H.R. 4333 (The Technical Corrections Act of 1988) Jcx-11-88?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
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