Tax Reform for Fairness, Simplicity, And Economic Growth : the Treasury Department Report to the President Vol. 1. Overview

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Tax deferral and conversion of ordinary income to capital gains occur together when accelerated depreciation deductions are used to offset ordinary wage and salary income, while a significant portion of the annual return on the investment is realized as preferentially taxed long-term capital gain at some future date.
Moreover, when taxation of income from an asset can be deferred or converted into tax-preferred income, investors will often have a strong incentive to finance the acquisition of t
...he asset by means of borrowing, as this allows the investor to engage in interest-related tax arbitrage. Interest-related tax arbitrage transactions occur when an investor borrows funds, fully deducts the interest expenses incurred to borrow those funds, and then uses the funds to purchase investments which earn either partially or entirely tax-exempt or tax- deferred income.
It is the combination of tax deferral and leveraged financing which is the principal cause of the substantial losses reported by tax shelter partnerships in the aforementioned three industries — some $33 billion in 1982.


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