Section of Taxation
Government Submissions

TAX SIMPLIFICATION RECOMMENDATIONS
Posted February 2001

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Attribution Rules

Harmonize the attribution rules. 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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