The Proposed Tax Straddle Reform Act of 1983- Unjust Treatment for Many U.S.-Owned Foreign Corporations
Article Abstract:
Congress enacted the Economic Recovery Tax Act of 1981 (ERTA) in part, to define legislation specifically related to commodity futures transactions and other personal property interests. One technique used by commodity investors is a tax straddle, which defers tax liability and sometimes even reduces taxes indefinitely. Some crafty futures traders have plotted to shield their investment income earned in the United States by using foreign-based corporations, which protects them from the ERTA provisions designed to regulate United States commodity futures transactions. In 1983, the Tax Straddle Reform Act was introduced to the Senate Finance Committee to reduce the chances of this happening. While certain parts of the Tax Straddle Reform Act are valid in cracking down on this situation, it also unjustly steps on the toes of corporations who are legally running foreign-based corporations.
Publication Name: Taxes: The Tax Magazine
Subject: Law
ISSN: 0040-0181
Year: 1984
User Contributions:
Comment about this article or add new information about this topic:
The Possessions and Virgin Islands Corporations Taxation Provisions of TEFRA
Article Abstract:
The United States tax laws concerning United States possessions' corporations and Virgin Islands' corporations have had some important revisions made to them by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). On January 5, 1984, TEFRA made specific regulations on the taxation of United States possessions' corporations and Virgin Islands' corporations. Two major changes have been made: the conditions that must be satisfied to make the possessions' corporation eligible for the possessions' tax credit and the treatment of certain tangible related income of the possessions' corporation. The new rulings could have a significant impact on United States corporations considering starting operations in the possessions or the Virgin Islands. Also, United States corporations already having operations in the possessions or the Virgin Islands might need to reassess their positions.
Publication Name: Taxes: The Tax Magazine
Subject: Law
ISSN: 0040-0181
Year: 1984
User Contributions:
Comment about this article or add new information about this topic:
Amortization of a Retained Terminable Interest after Transfer of a Remainder
Article Abstract:
In the case of Lomas Santa Fe Incorporated, the issue was whether or not a taxpayer holding land could transfer the remainder interest and retain a term interest in the property. By doing this, the taxpayer could amortize the term interest, without retaining the underlying asset. The tax court decision was, that a taxpayer could not sell the remainder interest and retain the term interest to amortize. The court reasoned that by doing this, the taxpayer has tried to take land, a nondepreciable asset, and turn it into a depreciable asset by splitting the property rights in two parts. The court contends that depreciability cannot be voluntarily transferred. However, conflict arises with this decision, in that this denial may not be consistent with the predominant pattern of tax law.
Publication Name: Taxes: The Tax Magazine
Subject: Law
ISSN: 0040-0181
Year: 1984
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: The Taxpayer Relief Act of 1997 contains a litany of amendments, many of which will affect the types of business entities in which attorneys practice
- Abstracts: When do franchisors have market power? Antitrust remedies for franchisor opportunism. Brand marketing, intrabrand competition, and the multibrand retailer: the antitrust law of vertical restraints
- Abstracts: More sunshine laws proposed; after the Firestone recalls, 10 states and the U.S. Senate introduced bills to limit secret orders, agreements
- Abstracts: The Andean Trade Preference Act: past accomplishments and present circumstances warrant its immediate renewal and expansion
- Abstracts: "Enhanced scrutiny" - Delaware's judicial standard of review for a single bid corporate acquisition?