Loopholes > Federal > Merchant Marine Capital Construction Fund (CCF) Deposits
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Merchant Marine Capital Construction Fund (CCF) Deposits

IRC §7518

Taxpayers can reduce their taxable income by depositing earnings from the operation of agreement vessels into a Capital Construction Fund. These deposits, along with earnings on the fund assets, are excluded from gross income.

Eligibility

Owners or lessees of 'agreement vessels' (including certain barges and containers) operating in U.S. foreign/domestic commerce or fisheries who enter into a specific agreement with the Secretary of Transportation or Commerce.

Frequently Asked Questions

Who is eligible for the Merchant Marine Capital Construction Fund (CCF) Deposits?

Owners or lessees of 'agreement vessels' (including certain barges and containers) operating in U.S. foreign/domestic commerce or fisheries who enter into a specific agreement with the Secretary of Transportation or Commerce.

How does the Merchant Marine Capital Construction Fund (CCF) Deposits work?

Taxpayers can reduce their taxable income by depositing earnings from the operation of agreement vessels into a Capital Construction Fund. These deposits, along with earnings on the fund assets, are excluded from gross income.

What law authorizes the Merchant Marine Capital Construction Fund (CCF) Deposits?

The Merchant Marine Capital Construction Fund (CCF) Deposits is authorized under IRC §7518 of the Internal Revenue Code (Title 26, United States Code).

Statutory Text — IRC §7518

Source: Internal Revenue Code, Title 26, United States Code

§ 7518. Tax incentives relating to merchant marine capital construction funds(a) Ceiling on deposits(1) In generalThe amount deposited in a fund established under chapter 535 of title 46 of the United States Code (hereinafter in this section referred to as a “capital construction fund”) shall not exceed for any taxable year the sum of:(A) that portion of the taxable income of the owner or lessee for such year (computed as provided in chapter 1 but without regard to the carryback of any net operating loss or net capital loss and without regard to this section) which is attributable to the operation of the agreement vessels in the foreign or domestic commerce of the United States or in the fisheries of the United States, (B) the amount allowable as a deduction under section 167 for such year with respect to the agreement vessels, (C) if the transaction is not taken into account for purposes of subparagraph (A), the net proceeds (as defined in joint regulations) from—(i) the sale or other disposition of any agreement vessel, or (ii) insurance or indemnity attributable to any agreement vessel, and (D) the receipts from the investment or reinvestment of amounts held in such fund. (2) Limitations on deposits by lesseesIn the case of a lessee, the maximum amount which may be deposited with respect to an agreement vessel by reason of paragraph (1)(B) for any period shall be reduced by any amount which, under an agreement entered into under chapter 535 of title 46, United States Code, the owner is required or permitted to deposit for such period with respect to such vessel by reason of paragraph (1)(B). (3) Certain barges and containers includedFor purposes of paragraph (1), the term “agreement vessel” includes barges and containers which are part of the complement of such vessel and which are provided for in the agreement. (b) Requirements as to investments(1) In generalAmounts in any capital construction fund shall be kept in the depository or depositories specified in the agreement and shall be subject to such trustee and other fiduciary requirements as may be specified by the Secretary.

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