Summary of H.R. 3838 (Tax Reform Act of 1986) : As Reported By the Senate Committee Finance Jcs-12-86
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Interest payments of foreign corporations are subject to tax if 10 percent of their income (rather than 50 percent as under present law) has a U.S. connection. The bill provides anti-treaty shopping rules. These rules are effective for taxable years beginning after 1986.
2. Repeal of FIRPTA.— The bill repeals the Foreign Investors in Real Property Tax Act (FIRPTA), which now taxes foreign inves- tors on their dispositions of U.S. real property interests. The repeal applies to dispositions after... 1986.
S. Retain character of effectively connected income. — The bill treats income or gain as effectively connected with a U.S. trade or business if it is attributable to a different taxable year and would have been so treated if it had been taken into account in the other year. Removal of an asset from U.S. tax jurisdiction by a foreign person is a taxable event. These rules apply to taxable years begin- ning after 1986.
4- Tax-free exchanges by expatriates. — The tax-avoidance expatri- ate rules under present law are applied to gains on the sale of property the basis of which was determined by reference to U.S.
What to read after Summary of H.R. 3838 (Tax Reform Act of 1986) : As Reported By the Senate Committee Finance Jcs-12-86?
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:
Interest payments of foreign corporations are subject to tax if 10 percent of their income (rather than 50 percent as under present law) has a U.S. connection. The bill provides anti-treaty shopping rules. These rules are effective for taxable years beginning after 1986.
2. Repeal of FIRPTA.— The bill repeals the Foreign Investors in Real Property Tax Act (FIRPTA), which now taxes foreign inves- tors on their dispositions of U.S. real property interests. The repeal applies to dispositions after... 1986.
S. Retain character of effectively connected income. — The bill treats income or gain as effectively connected with a U.S. trade or business if it is attributable to a different taxable year and would have been so treated if it had been taken into account in the other year. Removal of an asset from U.S. tax jurisdiction by a foreign person is a taxable event. These rules apply to taxable years begin- ning after 1986.
4- Tax-free exchanges by expatriates. — The tax-avoidance expatri- ate rules under present law are applied to gains on the sale of property the basis of which was determined by reference to U.S.
What to read after Summary of H.R. 3838 (Tax Reform Act of 1986) : As Reported By the Senate Committee Finance Jcs-12-86?
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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