Edward A. Robinson III and Diana R. Robinson - Page 98




                                        - 72 -                                         
               Section 119 of the bills provided that these amendments                 
          “shall take effect as if included in the provision of the Reform             
          Act to which such amendment relates.”                                        
               On June 15, 1987, the staff of the Joint Committee on                   
          Taxation released its Description of the Technical Corrections               
          Act of 1987 (H.R. 2636 and S. 1350) (JCS-15-87), June 15, 1987.              
          At pages 25 and 26, this staff pamphlet describes the above                  
          amendments as follows:                                                       
                              Explanation of Provisions                                
                    Investment interest.–-The bill conforms the                        
               language of the definition of investment interest to                    
               the language of a related provision that allocates                      
               interest expense to portfolio income under the passive                  
               loss rule.  Thus, under the bill, investment interest                   
               is that which is properly allocable to property held                    
               for investment.  This change results in consistency in                  
               the language of the provisions allocating interest                      
               expense to the category of investment interest, and                     
               permits consistent application of a standard for                        
               allocation of interest.  This change is not intended to                 
               suggest the adoption of any particular method of                        
               allocation, but rather to give Treasury the ability to                  
               devise allocation rules as simple as possible                           
               consistent with the objectives of the provision.                        
                           *    *    *    *    *    *    *                             
                    Personal interest.–-The bill conforms the language                 
               of the definition of personal interest to the language                  
               of related provisions (the passive loss rule and the                    
               investment interest limitation) under which interest                    
               expense may be allocated.  Thus, the bill provides that                 
               personal interest does not include interest that is                     
               properly allocable to a trade or business.  This change                 
               results in consistency in the language of several                       
               significant provisions under which interest is likely                   
               to be allocated, and permits consistent application of                  
               a standard for allocation of interest.                                  






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