Comments on New Proposed Regulations Under Section 897

Article Abstract:

In November of 1983, the Internal Revenue Service (IRS) printed new proposed rules pertaining to sections 897 of the Internal Revenue Code (IRC). These will take the place of former proposals issued in September, although they are in effect at present. Their effect has little practical value. The repropsals have some significant differences from the former ones, particularly as to definitions of real property, assets used or held by a business, and those regularly traded on established securities markets. Real property will not entail natural products following harvest or extraction. Improvements to land are defined as other tangible property. Personal property linked to the use of real property will be regarded as tangible personal property. It will be treated as real property only when owned by the same party who owns the real estate involved. Fair market value determinations will be used to determine the validity of real property holding corporations.

Analysis, Securities, Property taxes, Property tax, Property

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Comments on Proposed Amendments to Section 367

Article Abstract:

The proposals of the Deficit Reduction Package introduced in late 1983 asked for broad alterations of Section 367 (a). Such proposals have wide impact possibilities for international business. Four changes would be made: cessation of the ruling requirement, the principal tax avoidance purpose standard and an establishment of an automatic to charge. Recent court decisions have been to the tax payers' benefit and the United States Treasury and Internal Revenue Service's (IRS) dismay. Related burden of proof principles are analyzed. A staff report did not address difficulties related to stock, securities, and intangibles. A recently proposed amendment speaks to an automatic fall change on outbound transfers of intangibles.

International aspects, Securities law, Commerce, Deficit financing, Deficit spending

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