Explanation of Miscellaneous Tax Proposals Scheduled for Hearings Before the Subcommittee On Select Revenue Measures of the House Committee On Ways And Means On February 21-22, 1990 Jcs-4-90

Cover Explanation of Miscellaneous Tax Proposals Scheduled for Hearings Before the Subcommittee On Select Revenue Measures of the House Committee On Ways And Means On February 21-22, 1990 Jcs-4-90
Explanation of Miscellaneous Tax Proposals Scheduled for Hearings Before the Subcommittee On Select Revenue Measures of the House Committee On Ways And Means On February 21-22, 1990 Jcs-4-90
United States. Congress. Joint Committee On Taxation
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553(a)(1)). As such, the term includes interest earned by a foreign corporation in the ordinary course of its business as a broker or dealer of securities.
The Code provides rules for personal holding companies (PHCs), that is, domestic corporations that are closely held and which earn significant passive-type income (sees. 541-547), that are in some ways similar to the FPHC rules. For purposes of the PHC rules, in- terest received by brokers or dealers in connection with securities * For certa
...in taxable years subsequent to a taxable year for which a corporation qualifies as an FPHC, the 60-percent threshold is reduced to 50 percent.
13 or money market instruments held as inventory, margin accounts, or any financing for a customer which is secured by securities or money market instruments is excluded from the types of passive income which can cause a company to be treated as a PHC.
Conversely, subpart F of the Code contains other rules designed to limit the opportunities of U.S. persons to defer the recognition of taxable income by conducting operations through a controlled for- eign corporation (sees.


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