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Proposed regulations on credit or refund of WPT to trust beneficiaries: how do they spell relief

Journal Article · · Oil Gas Tax Q.; (United States)
OSTI ID:5535571
Small royalty owners obtained partial relief from the Windfall Profits Tax (WPT) under the Internal Revenue Code Section 6429 of 1980, the Technical Corrections Act of 1982, and the Treasury's proposed regulations of 1984. After a close examination of the law, the authors discuss the regulations in general and some issues and questions not clarified by the regulations. They find that for WPT purposes only, a fiduciary of a fiscal-year trust will have to combine part of the information from two trust accounting periods to prepare a proper Form 6248. To add the requirement that a cash-basis trust use the accrual method of accounting does not conform to the spirit of a law that was intended to be simple and provide relief.
Research Organization:
Peat, Marwick, Mitchell and Co., Houston, TX
OSTI ID:
5535571
Journal Information:
Oil Gas Tax Q.; (United States), Journal Name: Oil Gas Tax Q.; (United States) Vol. 33:4; ISSN OGTQD
Country of Publication:
United States
Language:
English