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Thoroughbred Horse Racing And Breeding As A Tax Sheltered Investment: Recent Tax Law Developments, Joel B. Turner
Thoroughbred Horse Racing And Breeding As A Tax Sheltered Investment: Recent Tax Law Developments, Joel B. Turner
Golden Gate University Law Review
This comment will first discuss principal tax shelter methods in general terms and then address the effects of recent tax legislation on tax-sheltered investments. Finally, the application of the current rules to hypothetical thoroughbred tax-sheltered investments will be undertaken to illustrate some of the options available to investors.
Nonrecourse Financing And Tax Shelter Abuse: The Crane Doctrine Before And After The At Risk Provisions, Michael Gurwitz
Nonrecourse Financing And Tax Shelter Abuse: The Crane Doctrine Before And After The At Risk Provisions, Michael Gurwitz
Golden Gate University Law Review
This Comment will examine the history of nonrecourse financing and tax shelters from the fabled Crane holding to the new reality of the ARP. This will be done by dividing the Comment into four parts. Part I will discuss the period preceding the passage of the Tax Reform Act of 1976, focusing on the Crane doctrine and subsequent attempts by the Internal Revenue Service (IRS) to define and limit the use of nonrecourse debt. Part II will highlight the factors that contributed to the growing abuse of tax shelters. Part III, in general terms, will examine the statutory scheme of …