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Annual Survey Of Virginia Law: The Virginia Limited Liability Company Act, S. Brian Farmer, Louis A. Mezzullo
Annual Survey Of Virginia Law: The Virginia Limited Liability Company Act, S. Brian Farmer, Louis A. Mezzullo
University of Richmond Law Review
Since the passage of the sixteenth amendment' in 1913 and the income tax legislation adopted thereunder, the development of new forms of business entities has been driven largely by the desire to harmonize two goals: limited liability for the owners of the entity and pass-through treatment of the entity for income tax purposes.
The Like-Kind Exchange Of Partnership Interests Under Irc Section 1031(A)(2)(D): An Historical Analysis Of Alternative Approaches, Vincent John Piazza
The Like-Kind Exchange Of Partnership Interests Under Irc Section 1031(A)(2)(D): An Historical Analysis Of Alternative Approaches, Vincent John Piazza
University of Richmond Law Review
Before the Tax Reform Act of 1984, general partnership interests were considered like-kind property which could be exchanged tax-free under Internal Revenue Code ("IRC") section 1031(a). Prior to 1984, the Internal Revenue Service ("IRS") had tried unsuccessfully to convince the courts that the parenthetical clause of section 1031(a), which excludes certain exchanges of interests from the definition of like-kind property, encompassed all types of equity interests. Since the IRC did not specifically exclude partnership interests, judges were very reluctant to adopt the IRS's over-expansive reading of the statute. After making very little headway with the courts, the IRS and treasury …