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This bulletin presents announcements of official rulings and procedures, treasury decisions, executive orders, tax conventions, legislation, and court decisions. It also contains other items of general interest intended to promote a uniform application of the tax laws.
Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d) (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d) (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary Income Tax Regulations regarding the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Internal Revenue Code (Code). Section 404 of the American Jobs Creation Act of 2004 (AJCA) reduced the number of section 904(d) separate categories from eight to two, effective for taxable years beginning after December 31, 2006. These temporary regulations affect taxpayers claiming foreign tax credits and provide guidance needed to comply with the statutory changes made by the AJCA. The text of these temporary regulations also serves as the text of the proposed regulations (REG-114126-07) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register. This book contains: - The complete text of the Reduction of Foreign Tax Credit Limitation Categories Under Section 904(d) (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
In A Good Tax, tax expert Joan Youngman skillfully considers how to improve the operation of the property tax and supply the information that is often missing in public debate. She analyzes the legal, administrative, and political challenges to the property tax in the United States and offers recommendations for its improvement. The book is accessibly written for policy analysts and public officials who are dealing with specific property tax issues and for those concerned with property tax issues in general.
The gift tax was first enacted in 1924, repealed in 1926, overhauled and reintroduced in 1932. At its peak in fiscal year 1999, it raised $4.6 billion in revenues, before the recent phased-in tax rate reductions ushered by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) took effect. It is noteworthy that the gift tax was first enacted as a protective measure to minimize estate and income tax avoidance, and not for its direct revenue yield. Similarly, EGTRRA, while phasing out the estate tax, retained the gift tax for the very same reasons. Unlike the estate tax which faces an uncertain future, the gift tax is little affected by recent legislative proposals and will remain part of the tax code for the foreseeable future. Nevertheless, the gift tax has been the subject of little scrutiny and studies of its economic implications are rare. This paper is an attempt to fill this void. It traces the evolution of the gift tax since its inception, and sketches out the structure of the tax and its complex interactions with the income and estate taxes. The paper also provides an overview of the direct fiscal contribution of the gift tax, and traces the number of taxpayers over time as well as their attributes. It concludes with a discussion of the behavioral effects of the gift tax and a review of the scant literature. These include empirical evidence on the choice between gifts and bequests, timing of gifts, and compliance among others.