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Subject Matter: |
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Attribution Rules |
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Brief Description of Issue (include examples if available): |
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The attribution rules throughout the Code contain myriad distinctions, many of which may have been reasonably fashioned in light of the particular concern the underlying provision initially addressed. It is not clear, however, that those reasons justify the complexity they create. The attribution rules should be reexamined in light of their underlying concerns with the objective of harmonizing and standardizing them. Further reexamination may permit the development of a single, uniform set of rules. Even without reexamination, they could be simplified by standardizing throughout the Code how the ownership percentages apply, i.e., whether the percentage under a particular attribution rule is "equal to" or "greater than." |
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Proposed Legislative Change: |
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Harmonize the attribution rules. |
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Benefits/Impact of Legislative Change (include the number of taxpayers impacted if known):
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Reduce complexity and enhance compliance. |
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Internal Revenue Code Cites. Please attach any reference material |
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Code sections 318, 707(b), etc. |