Charles C. Allen, III and Barbara N. Allen, et al. - Page 32




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                    Corporations.--Generally, the tax base for the                      
               alternative minimum tax on corporations is the                           
               taxpayer’s regular taxable income, increased by the                      
               taxpayer’s tax preferences for the year and adjusted by                  
               computing certain deductions in a special manner which                   
               negates the acceleration of such deductions under the                    
               regular tax.  The resulting amount, called alternative                   
               minimum taxable income, then is reduced by a $40,000                     
               exemption and is subject to tax at a 25-percent rate.                    
               The amount so determined may then be offset by the                       
               minimum tax foreign tax credit to determine a                            
               “tentative minimum tax.”  These rules are designed to                    
               ensure that, in each taxable year, the taxpayer must                     
               pay tax equaling at least 25 percent of an amount more                   
               nearly approximating its economic income (above the                      
               exemption amount).                                                       
                    The net minimum tax, or amount of minimum tax due,                  
               is the amount by which the tax computed under this                       
               system (the tentative minimum tax) exceeds the                           
               taxpayer’s regular tax.  Although the minimum tax is,                    
               in effect, a true alternative tax, in the sense that it                  
               is paid only when it exceeds the regular tax,                            
               technically the taxpayer’s regular tax continues to be                   
               imposed, and the net minimum tax is added on.                            
                    Individuals.-–The structure for the alternative                     
               minimum tax on individuals generally is the same as                      
               under present law, except that certain deferral                          
               preferences (such as incentive depreciation) give rise                   
               to adjustments to the minimum tax base over a period of                  
               years, in order properly to compute total income each                    
               year in light of the fact that, in later years, the                      
               regular tax deduction typically is smaller than the                      
               deduction would be if calculated on a straight line                      
               basis over a longer period.  The alternative minimum                     
               tax on individuals differs from that applying to                         
               corporations in several respects.  For example, there                    
               are some differences between the preferences applying                    
               to individuals and those applying to corporations, and                   
               certain itemized deductions that individuals can claim                   
               for regular tax purposes are not allowable under the                     
               minimum tax.   [H. Rept. 99-426, at 308 (1986), 1986-3                   
               C.B. (Vol. 2) 308; emphasis added.]                                      









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