Interest Expense

Interest Expense
Author: United States. Internal Revenue Service
Publisher:
Total Pages: 4
Release: 1980
Genre: Income tax deductions
ISBN:

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Interest Expense

Interest Expense
Author: United States. Internal Revenue Service
Publisher:
Total Pages: 16
Release: 1988
Genre: Income tax
ISBN:

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Income Tax Deduction for Interest Expense

Income Tax Deduction for Interest Expense
Author: United States. Internal Revenue Service
Publisher:
Total Pages: 8
Release: 1978
Genre: Income tax deductions for interest
ISBN:

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Interest Expense Deductions

Interest Expense Deductions
Author: Dominic L. Daher
Publisher:
Total Pages:
Release: 2007-01-01
Genre: Income tax deductions for interest
ISBN: 9781558715776

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"... describes in detail the basic rules relating to the allowance of and limitations on deductions for interest expenses as set forth in the Internal Revenue Code and Treasury Regulations. Coverage includes: (1) the determination of whether payments are interest in form but not in substance, or vice versa; (2) the measurement and timing of interest deductions; (3) the investment interest limitation; (4) the nondeductibility of personal interest, including the "qualified residence interest" exception; (5) the various provisions for imputation of interest, including imputation of interest on certain types of below-market loans; (6) the interest capitalization rules; and (7) a survey of provisions disallowing interest. "

Interest as a Cost

Interest as a Cost
Author: Clinton Homer Scovell
Publisher:
Total Pages: 276
Release: 1924
Genre: Accounting
ISBN:

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Interest Expense

Interest Expense
Author: United States. Internal Revenue Service
Publisher:
Total Pages: 4
Release: 1980
Genre: Income tax deductions for interest
ISBN:

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Farmer's Tax Guide

Farmer's Tax Guide
Author:
Publisher:
Total Pages: 112
Release: 1998
Genre: Agriculture
ISBN:

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United States Code

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

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"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.

Determining Interest Expense Incurred by Affiliated Corporations to Earn Tax-Exempt Income

Determining Interest Expense Incurred by Affiliated Corporations to Earn Tax-Exempt Income
Author: W. Eugene Seago
Publisher:
Total Pages: 0
Release: 2005
Genre:
ISBN:

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The article first discusses the various approaches the courts and the IRS have used to relate interest expense to tax-exempt interest income. In some instances a tracing of loan proceeds to the purchase of the tax-exempt obligations is required before any of the interest expense is denied. In other instances a formula approach is applied to disallow a portion of the interest. When one entity borrows funds and a related entity earns tax-exempt income, relating the expense and income becomes even more complicated. The Tax Court has provided some guidance in H Enterprises International, Inc. I (105 T.C. 71, 1995) and II (TCM 1998-97). The Service amplified the reasoning in these decisions in Revenue Ruling 2004-47, and in recently proposed regulation 1.265-2(c)(1). The authors note that the tendency is for the Service to apply a single-entity approach. This is especially problematic for banks and other financial institutes are required by section 265(b) to apply a formula to determine the interest expense to purchase or carry the tax-exempt obligations. A combination of market forces that reduce the yield on exempt obligations, and tax rules that cause an automatic disallowance interest expense, effectively eliminates financial institutions from tax-exempt investing. This has implications for state and local government borrowers as well as the Treasury.

Income Tax Deduction for Interest Expense

Income Tax Deduction for Interest Expense
Author: United States. Internal Revenue Service
Publisher:
Total Pages: 0
Release: 1977
Genre: Income tax deductions
ISBN:

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