Debt-financed Income

Debt-financed Income
Author: Carla Neeley Freitag
Publisher:
Total Pages:
Release:
Genre: Charitable uses, trusts, and foundations
ISBN: 9781633590151

... describes and analyzes the tax treatment of income and deductions attributable to debt-financed assets owned by exempt organizations. Notwithstanding their general exemption from income taxation, exempt organizations are nevertheless subject to the unrelated business income tax, which taxes income from a regularly conducted trade or business that is unrelated to an organization's exempt purpose or function. Most passive investment income, such as dividends, interest, and rents, is excepted from the scope of the unrelated business income tax. If, however, investment income is derived from debt-financed property, all or part of the income and deductions with respect to the property must be included in computing unrelated business taxable income. The purpose of the debt-financed property rules is to prevent exempt organizations from unfairly competing with their taxable counterparts in the acquisition of businesses and other investment assets that are debt-financed.

Unrelated Debt-financed Income of Tax-exempt Organizations

Unrelated Debt-financed Income of Tax-exempt Organizations
Author: United States. Congress. House. Committee on Ways and Means
Publisher:
Total Pages: 76
Release: 1966
Genre: Tax exemption
ISBN:

Considers H.R. 15942 and identical H.R. 15943, to tax tax-exempt organizations' income generated from business not related to the organizations' charitable functions, including investment borrowing.

United States Code

United States Code
Author: United States
Publisher:
Total Pages: 1506
Release: 2013
Genre: Law
ISBN:

"The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.

Handbook of Debt Management

Handbook of Debt Management
Author: Gerald J. Miller
Publisher: Routledge
Total Pages: 992
Release: 2017-07-05
Genre: Political Science
ISBN: 1351564633

Examining various methods of debt management used in the US., Handbook of Debt Management, provides a comprehensive analysis of securities offered for sale by municipalities, states, and the federal government. The book covers laws regarding municipal bonds, the economic choice between debt and taxes and the tax-exempt status of municipal bond owners, capital budgeting, including state and local government practices, developing governmental and intergovernmental debt policies, pay-as-you-go with debt financing for capital projects, US Internal Revenue Service regulations on arbitrage in state and local government debt proceeds investment, US treasury auctions, and more.

Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States

Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States
Author: International Monetary Fund
Publisher: International Monetary Fund
Total Pages: 64
Release: 1990-07-01
Genre: Business & Economics
ISBN: 1451961928

The classical corporate profits tax in the United States involves non-neutralities between: different sources of financing; different forms of business organization; and retaining or distributing earnings and may result in the U.S. investor being at a disadvantage vis-à-vis foreign investors. An international comparison is provided, and the potential effects of different integration schemes on the user cost of capital and tax revenues are assessed. The integration of corporate and individual income taxes in the United States could lead to a more efficient domestic and worldwide allocation of resources.