- 14 - ordinary income. See sec. 163(d)(3)(B), I.R.C. 1954, as amended by TRA 1969. In 1976, Congress revised section 163(d) to reduce the use of this deduction to shelter noninvestment types of income.14 See sec. 209(a) of the Tax Reform Act of 1976 (TRA 1976), Pub. L. 94-455, 90 Stat. 1542. The definition of investment income remained unchanged, but the TRA 1976 amendment eliminated any offset of investment interest expense against long-term capital gain. Id. In 1986, Congress expanded the scope of the investment interest expense limitation and altered the calculation of the limitation by including “any net gain attributable to the disposition of property held for investment”. Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, sec. 511(a), 100 Stat. 2320; see H. Conf. Rept. 99-841 (1986), 1986-3 C.B. (Vol. 4) 152, wherein the conference committee articulated the intent to expand the definition of investment income “to include the same items as under * * * [TRA 1976] plus the taxable portion of net gain from the disposition of investment property.”15 (Emphasis added.) 14 See H. Rept. 94-658, at 102, 1976-3 C.B. (Vol. 2) 695, 794; S. Rept. 94-938, at 106, 1976-3 C.B. (Vol. 3) 49, 144; Staff of Joint Comm. on Taxation, General Explanation of the Tax Reform Act of 1976, at 103 (J. Comm. Print 1976). 15 See also H. Rept. 99-426, at 300 (1986) (“[investment income] also includes the nondeductible portion of net long-term capital gain on investment property.”); S. Rept. 99-313, at 805 (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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