H.R.2069 - A bill to amend the Internal Revenue Code of 1954 to make permanent the rules relating to imputed interest and assumption of loans, and for other purposes.99th Congress (1985-1986)
|Sponsor:||Rep. Matsui, Robert T. [D-CA-3] (Introduced 04/17/1985)|
|Committees:||House - Ways and Means|
|Latest Action:||House - 04/24/1985 Committee Hearings Held. (All Actions)|
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Summary: H.R.2069 — 99th Congress (1985-1986)All Information (Except Text)
Introduced in House (04/17/1985)
Amends the Internal Revenue Code to establish an applicable test rate of nine percent for determining whether there is imputed interest in the case of seller-financed property. Permits a lower test interest rate of 80 percent of the Federal Treasury rate where such rates are lower than the nine percent test rate. Provides for a blended test rate for instances where the loan amount exceeds $4,000,000. Provides that in determining whether wraparound financing meets such testing rate, the test shall be applied to the net rate of interest on the seller's equity in the financing after deducting the existing third party financing.
Authorizes the imputation of interest in seller-financed property sales of $4,000,000 or less of ten percent or 90 percent of the Federal Treasury rates, whichever is less, where the test interest rates have not been met. Allows for a blended imputed interest rate where the debt amount exceeds $4,000,000.
Requires that all loan amounts from a single transaction or series of related transactions be aggregated for purposes of determining the loan amount. Provides that the imputed interest rules will not apply to assumptions of loans unless the terms and conditions of such debt obligations are modified in connection with the assumption.
Repeals the provisions of the Code limiting the amount of interest expense a purchaser of personal use property may deduct for tax purposes.
Excepts debt instruments arising from the sale or exchange of a residence from the imputed interest provisions where the obligor of the instrument uses the property as his other residence.
Provides that the imputed interest rules shall not apply in the case of sales or exchanges of property where the borrowed amount does not exceed $4,000,000. Requires the interest on the obligation issued in connection with such sales or exchanges to be taken into account by both the buyer and the seller on the cash receipts and disbursement method of accounting unless both buyer and seller agree to use the accrual receipts and disbursement method of accounting.