- 22 - section 267 had long included certain controlled corporations within the definition of related parties under section 267(b) that were subject to the general loss disallowance and gain adjustment provisions of subsections (a)(1) and (d).10 When Congress created the special rules of section 267(f), it also enlarged the class of controlled corporations defined as related parties, to curb further the sorts of abuses that section 267 was meant to address: Congress believed that certain related parties, such as * * * controlled corporations should be made subject to the related party rules in order to prevent tax avoidance on transactions between those parties. [Staff of Joint Comm. on Taxation, General Explanation of the Revenue Provisions of the Deficit Reduction Act of 1984, at 542 (J. Comm. Print 1985).] The House bill would have simply applied the general loss disallowance rules of section 267(a)(1) to the expanded class of controlled corporations.11 The Senate bill followed the House 10 Prior to amendment in 1984, sec. 267(b)(3) defined as related taxpayers: Two corporations more than 50 percent in value of the outstanding stock of each of which is owned, directly or indirectly, by or for the same individual, if either one of such corporations, with respect to the taxable year of the corporation preceding the date of the sale or exchange was, under the law applicable to such taxable year, a personal holding company or a foreign personal holding company. 11 The House report stated: the bill extends the loss disallowance and accrual (continued...)Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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