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Full-Text Articles in Law
Guidance Is Definitive, Reality Is Frequently Inaccurate: The Lingering Saga Of Rev. Rul. 91-32, Robert L. Daily
Guidance Is Definitive, Reality Is Frequently Inaccurate: The Lingering Saga Of Rev. Rul. 91-32, Robert L. Daily
Georgia Law Review
Partnership and international taxation are two of the
most mind-numbing and inconsistent areas of the law.
Even more confusion occurs when the two intersect, such
as when a nonresident sells an interest in a U.S.
partnership. Many have wasted precious time and
abundant ink to come up with a solution. The IRS first
tried in Rev. Rul. 91-32, concluding that a nonresident
would be subject to tax if the partnership had assets
producing income generated from property in United
States. Although the guidance was appropriately
criticized for being statutorily inconsistent, this Note
argues that it nonetheless got to the right …
A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie Hunter Mcmahon
A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie Hunter Mcmahon
Northwestern University Law Review
No abstract provided.
Passthrough Entities: The Missing Element In Business Tax Reform, Karen C. Burke
Passthrough Entities: The Missing Element In Business Tax Reform, Karen C. Burke
Pepperdine Law Review
Reform of the U.S. corporate tax system is again on the agenda. Despite important differences, many current proposals share two common goals: (1) reducing the statutory corporate tax rate to improve U.S. international competitiveness and (2) broadening the corporate tax base by reducing or eliminating business expenditures to offset revenue losses. Given the significance of the passthrough sector and the relationship between individual and corporate taxes, however, such reforms need to be considered within a broader context. Part I of this article discusses the growing significance of the passthrough sector, which now accounts for roughly half of net business income. …
Rolling Down The Curtain On "Roll-Ups": The Case For Federal Legislation To Protect Limited Partners, Kenneth R. Hillier
Rolling Down The Curtain On "Roll-Ups": The Case For Federal Legislation To Protect Limited Partners, Kenneth R. Hillier
Michigan Law Review
This Note examines roll-ups and the lack of alternatives available to reluctant limited partners. Part I focuses on existing judicial remedies for limited partners, such as injunctions and actions for damages, and explains why these courses of action provide inadequate protection. This Part then reviews recent attempts at statutory protection and points out the shortcomings of these remedies. Part II examines safeguards afforded analogously situated corporate shareholders and sets forth arguments why limited partners should receive similar protection. After demonstrating the need for legislation, Part III suggests a workable structure for this statutory protection. Then, the Note discusses the relative …
Disguised Sales Between Partners And Partnerships: Section 707 And The Forthcoming Regulations, Karen C. Burke
Disguised Sales Between Partners And Partnerships: Section 707 And The Forthcoming Regulations, Karen C. Burke
Indiana Law Journal
No abstract provided.
Tax Planning For Compensation Of Service Partners
Tax Planning For Compensation Of Service Partners
William & Mary Law Review
No abstract provided.
The Drafting Of Partnership Agreements Under The 1954 Internal Revenue Code, Robert S. Ashby, Albert L. Rabb Jr.
The Drafting Of Partnership Agreements Under The 1954 Internal Revenue Code, Robert S. Ashby, Albert L. Rabb Jr.
Indiana Law Journal
No abstract provided.
Income Tax Consequences Of Partnership Agreements Under The 1954 Internal Revenue Code, Earle B. Fowler, James T. Carey
Income Tax Consequences Of Partnership Agreements Under The 1954 Internal Revenue Code, Earle B. Fowler, James T. Carey
Kentucky Law Journal
No abstract provided.
Some Income Tax Aspects Of Community Property Law, Paul R. Trigg, Jr.
Some Income Tax Aspects Of Community Property Law, Paul R. Trigg, Jr.
Michigan Law Review
The recent enactment of community property law in Michigan and other states has created new problems for lawyers. Not the least of these is the question of the income tax consequences which flow from the existence of a community between the spouses. Nor is this the type of problem which can be shrugged off by reference to tax counsel. Local community property law and federal .income tax law are too closely enmeshed to be intelligently divided. No authority is needed for the statement that recently enacted community property laws are a product of high surtaxes. At the same time, these …
Taxation - Social Security - Dissolution Of Corporation And Formation Of Partnership As Means Of Avoiding Tax, Arthur P. Boynton
Taxation - Social Security - Dissolution Of Corporation And Formation Of Partnership As Means Of Avoiding Tax, Arthur P. Boynton
Michigan Law Review
The O Company surrendered its corporate charter and began operating under an agreement purporting to establish a partnership relation between the former officers and employees whereby complete management including the power to employ, discharge and control the duties of its members was vested in a "board of control" elected by and subject to changes made by the majority in interest. Net profits and losses were shared in proportion to the respective interests. The firm could be dissolved only by a vote of the majority in interest and not by transfer of interest, death or resignation of a member. Advice was …