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Full-Text Articles in Law
S Corporation Loss Limitations: The Tax Court Provides Potential Hope For Related Party Debt Restructurings, Francine J. Lipman
S Corporation Loss Limitations: The Tax Court Provides Potential Hope For Related Party Debt Restructurings, Francine J. Lipman
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No abstract provided.
Never-Ending Limitations On S Corporation Losses: The Slippery Slope Of S Corporation Debt Guarantees, Francine J. Lipman
Never-Ending Limitations On S Corporation Losses: The Slippery Slope Of S Corporation Debt Guarantees, Francine J. Lipman
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Francine Lipman explains S corporation loss limitations in the area of shareholder guarantees, focusing on the recent tax court and seventh circuit decisions in T.F. Grojean and concludes with a summary of the lessons s corporation shareholders can learn from the Grojeans' missteps.
Incentive Stock Options And The Alternative Minimum Tax: The Worst Of Times, Francine J. Lipman
Incentive Stock Options And The Alternative Minimum Tax: The Worst Of Times, Francine J. Lipman
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Congress enacted the Alternative Minimum Tax ("AMT") to stop high-income individuals from escaping their tax liabilities through tax code loopholes. In recent years, increasing numbers of moderate-income taxpayers have been subject to astronomical AMT liabilities. The problem has been especially acute for technology sector employees who exercised stock options while the market was high, sold their stock after its value fell, and found themselves owing AMT they could not afford to pay. In this Essay, Professor Lipman explains the Internal Revenue Code's complicated treatment of Incentive Stock Options ("ISOs"). She argues that the AMT adjustment for ISOs should not be …