rates significantly below historic averages, individuals have been encouraged to borrow at low cost to refinance their homes and other loans.
on required reserve balances, some of the retail sweep programs that have been implemented in recent years might be unwound, and new programs would be less likely to be implemented, thereby helping to boost the level of such balances.
For overlapping periods of underpayment and overpayment with interest
accruing prior to date of enactment, there is a special "transition" rule that applies for periods beginning before the date of enactment if the taxpayer reasonably "identifies and establishes" such periods and if the taxpayer requests that the section be applied to such periods.
In its congressionally mandated study of interest netting, the Treasury has concluded that new legislation should be enacted to deal with interest
on tax overpayments and underpayments during a time of mutual indebtedness.
From a tax policy perspective, the government or the taxpayer should be compensated with interest
only for the time the government has the use of the taxpayer's money or vice-versa.
Because wealth is the dominant source of structural variability, the policy-transmission channel associated with interest
rate effects on household wealth is more unpredictable in the 1980s.
Only after the Service initiated an examination were the notes repaid with interest
Suspension of capitalization begins with interest
incurred the 13th month following cessation of production.
Because a taxpayer who had not underpaid his tax could not get interest on a refund attributable to a carryback prior to the end of the carryback year, it seemed equitable to charge another taxpayer who had underpaid his tax with interest
on the underpayment extinguished by the carryback.
This negates any argument that interest expense may be netted with interest
Netting interest income with interest
expense subject to capitalization.