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Full-Text Articles in Law
The Problem Of Abusive Related-Partner Allocations, Gregg D. Polsky, Emily Cauble
The Problem Of Abusive Related-Partner Allocations, Gregg D. Polsky, Emily Cauble
Scholarly Works
This Article highlights a flaw in the existing rules regarding partnership tax allocations that has not yet received sufficient attention by existing literature. Namely, the partnership tax allocation rules are implicitly premised on the assumption that partners are unrelated and, thus, transact with each other at arm’s length. As a result, related partners can and do devise tax allocation schemes that exploit the gap in the current partnership tax allocation rules to achieve unwarranted tax savings.
This Article proposes to end this abuse by disallowing special allocations among related partners. Under the proposal, allocations among related partners would be required …
Municipal Demands As The Stimulus For Innovation: Tales From The Lower Colorado River Basin, Jerome C. Muys
Municipal Demands As The Stimulus For Innovation: Tales From The Lower Colorado River Basin, Jerome C. Muys
Water and Growth in the West (Summer Conference, June 7-9)
17 pages.
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
William & Mary Annual Tax Conference
No abstract provided.
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
William & Mary Annual Tax Conference
No abstract provided.