Examples of the 1986 Act in a sentence
The fresh start provision of section 1023(e)(3)(A) of the 1986 Act does not apply to the portion of the taxpayer’s unpaid losses attributable to reserve strengthening.
For purposes of section 1023(e)(3)(B) of the 1986 Act, the amount of reserve strengthening (weakening) must be determined separately for each unpaid loss reserve by applying the rules of this paragraph (c).
Notwithstanding this general rule, the 1986 Act taxes capital gains at the same rate as ordinary income beginning January 1, 1988.
It is anticipated that the 2013 Act will in time supersede the 1986 Act.
The six-page Preamble explains that the Section 482 regulations address how to allocate income and deductions with a focus on “high-profit intangibles” owned by controlled parties, which was a policy issue identified in connection with the enactment of the 1986 Act.