Omnibus Maritime Regulatory Reform, Revitalization, and Reorganization Act: Hearing Before the Committee on Ways and Means, House of Representatives, Ninety-sixth Congress, Second Session, on H.R. 4769 ... March 19, 1980U.S. Government Printing Office, 1980 - Всего страниц: 144 |
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Стр. 18
... base used for calculation of the investment tax credit an amount equal to those funds with- drawn from tax - deferred accounts.28 In Pacific , it was argued by the taxpayer that : 29 *** [ P ] laintiff's investment in its ships ...
... base used for calculation of the investment tax credit an amount equal to those funds with- drawn from tax - deferred accounts.28 In Pacific , it was argued by the taxpayer that : 29 *** [ P ] laintiff's investment in its ships ...
Стр. 20
... bases of the Purnell , Ashland and Fitzgerald were increased by the extent of approximately $ 1.6 million that plaintiff used to reconstruct these vessels . The adjusted basis of these vessels would have correspondingly increased had ...
... bases of the Purnell , Ashland and Fitzgerald were increased by the extent of approximately $ 1.6 million that plaintiff used to reconstruct these vessels . The adjusted basis of these vessels would have correspondingly increased had ...
Стр. 31
... bases in the ships , rather than upon only a ratable portion attributable to construction work done in 1962 as defendant contended . Pacific Far East Line , Inc. v . United States , 513 F.2d 1355 , 206 Ct . Cl . 378 ( 1975 ) .2 We shall ...
... bases in the ships , rather than upon only a ratable portion attributable to construction work done in 1962 as defendant contended . Pacific Far East Line , Inc. v . United States , 513 F.2d 1355 , 206 Ct . Cl . 378 ( 1975 ) .2 We shall ...
Стр. 40
... bases for the investment credit , the identical result must follow where the funds are used to reduce the mortgages . Once the bases of the vessels are determined and the investment credit calculated , we hold that the tax deferred ...
... bases for the investment credit , the identical result must follow where the funds are used to reduce the mortgages . Once the bases of the vessels are determined and the investment credit calculated , we hold that the tax deferred ...
Стр. 43
... base in the United States by which the American seaman is paid and the wage paid to seamen of controlled carriers , such as the Soviet Union . Seamen there are paid $ 100 a month . So we have those two subsidies , one operational and ...
... base in the United States by which the American seaman is paid and the wage paid to seamen of controlled carriers , such as the Soviet Union . Seamen there are paid $ 100 a month . So we have those two subsidies , one operational and ...
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1947 agreement accelerated depreciation Act-Sect AL ULLMAN allowed amended amount barge benefits bill bulk capital construction fund cargo CCF Program Chairman change from base closing agreement commerce Committee Compare Bill-Sect competitive Congress corporations court deposited Difference from base domestic trade earnings economic effect Federal flag vessels fleet foreign flag foreign shipping foreign trade GIBBONS GUARINI HALPERIN incentive income tax inland waterways Internal Revenue Code Internal Revenue Service investment credit investment tax credit Jones Act legislation liner Marine and Fisheries Maritime Administration MCCLOSKEY ment Merchant Marine Act million MURPHY ordinary income account Percent change plaintiff portion profits proposed purchase purposes qualified investment qualified withdrawals reciprocal exemption reduce reserve funds ROUSSELOT section 38 property Section 607 shippers shipping income subsidy summary judgment tax deferred tax provisions tax treaties tax-deferred funds taxable income taxpayer tion Title U.S. flag U.S. shipbuilding U.S. shipping U.S. tax U.S.-flag vessels United
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Стр. 16 - It is necessary for the national defense and development of its foreign and domestic commerce that the United States shall have a merchant marine (a) sufficient to carry its domestic waterborne commerce and a substantial portion of the water-borne export and import foreign commerce of the United States and to provide shipping service on all routes essential for maintaining the flow of such domestic and foreign water-borne commerce at all times, (b) capable of serving as a naval and military auxiliary...
Стр. 14 - estimated useful life", see paragraph (e) of § 1.46-3. (b) Depreciation allowable. (1) Property is not section 38 property unless a deduction for depreciation (or amortization in lieu of depreciation) with respect to such property is allowable to the taxpayer for the taxable year. A deduction for depreciation is allowable if the property is of a character subject to the allowance for depreciation under section 167 and the basis (or cost) of the property is recovered through a method of depreciation,...
Стр. 16 - That it is necessary for the national defense and for the proper growth of its foreign and domestic commerce...
Стр. 34 - The intention of the lawmaker controls in the construction of taxing acts as it does in the construction of other statutes, and that intention is to be ascertained, not by taking the word or clause in question from its setting and viewing it apart, but by considering it in connection with the context, the general purposes of the statute in which it is found, the occasion and circumstances of its use, and other appropriate tests for the ascertainment of the legislative will.
Стр. 16 - ... owned and operated under the United States flag by citizens of the United States, insofar as may be practicable, and (d) composed of the best-equipped, safest, and most suitable types of vessels, constructed in the United States and manned with a trained and efficient citizen personnel. It is declared to be the policy of the United States to foster the development and encourage the maintenance of such a merchant marine.
Стр. 18 - The objective of the credit is to reduce the net cost of acquiring new equipment; this will have the effect of increasing the earnings of new facilities over their productive lives and increasing the profitability of productive investment. It is your committee's intent that the financial assistance represented by the credit should itself be used for new investment, thereby further advancing the economy.
Стр. 16 - ... operated under the United States flag by citizens of the United States insofar as may be practicable, and (d) composed of the best-equipped, safest, and most suitable types of vessels, constructed in the United States and manned with a trained and efficient citizen personnel. It is hereby declared to be the policy of the United States to foster the development and encourage the maintenance of such a merchant marine.
Стр. 34 - States; (ii) rolling stock, of a domestic railroad corporation subject to part I of the Interstate Commerce Act, which is used within and without the United States; (iii) any vessel documented under the laws of the United States...
Стр. 22 - Realistic depreciation alone, however, is not enough to provide the essential economic growth. In addition, a specific incentive must be provided if a higher rate of growth is to be achieved. The investment credit will stimulate investment, first by reducing the net cost of acquiring depreciable assets, which in turn increases the rate of return after taxes arising from their acquisition.
Стр. 34 - Such term includes only property with respect to which depreciation (or amortization in lieu of depreciation) is allowable and having a useful life (determined as of the time such property is placed in service) of 4 years or more. (2) PROPERTY USED OUTSIDE THE UNITED STATES. — (A) In GENERAL. — Except as provided in snbparagraph (B), the term "section 38 property" does not include property which is used predominantly outside the United States.