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Full-Text Articles in Law

The Lingering Demise Of Tax Exempt Mutual And Captive Insurance Companies, Darryll K. Jones Jan 1995

The Lingering Demise Of Tax Exempt Mutual And Captive Insurance Companies, Darryll K. Jones

Journal Publications

Prior to the enactment of IRC §501(m), the issue of whether a group self-insurance pool was tax exempt generally depended upon an analysis of the "substantial purpose" requirement contained in Treasury Regulation §1.501(c)(3)-1(c)(1) which denies tax exempt status to an entity or organization if "more than an insubstantial part of its activities is not in furtherance of an exempt purpose." In addition, Treas. Reg. §1.501(c)(3)-1(e)(1) allows an entity to operate a trade or business as a substantial part of its activities but only "if the operation of such trade or business is in furtherance of the organization's exempt purpose.... Thus, …


The Separate Tax Status Of Loan-Out Corporations, Mary Lafrance Jan 1995

The Separate Tax Status Of Loan-Out Corporations, Mary Lafrance

Scholarly Works

When professionals and other persons who offer their goods and/or services to the public conduct their businesses through corporations, the Treasury has acknowledged that for federal income tax purposes it must treat those corporations as separate and distinct from their controlling shareholder-employees, even where there is only a single shareholder-employee, provided that the corporation has a business purpose and the taxpayer consistently respects the corporate form. However, the Treasury has refused to accord equal dignity to incorporated workers who offer their services not to the public at large but to a single recipient or a small number of recipients. The …


Comments On A Revised Filing System, R. Wilson Freyermuth Jan 1995

Comments On A Revised Filing System, R. Wilson Freyermuth

Faculty Publications

Professor Edward Adams's article, both in terms of its basic structure and the myriad of options it offers, neatly highlights the basic dilemma facing the Drafting Committee as it addresses the future Article 9 filing system. As he correctly notes, the filing system's shortcomings are largely due to its continued dependence on paper records, despite the increasing sophistication and availability of computerized information technology for both filing and searching. Should the Drafting Committee maintain the basics of the current system (a public, paper-based filing system) and merely attempt to identify and correct the existing shortcomings in that system, with some …


Is Compromise Of A Tax Liability Itself Taxable? A Problem Of Circularity In The Logic Of Taxation., Richard C.E. Beck Jan 1995

Is Compromise Of A Tax Liability Itself Taxable? A Problem Of Circularity In The Logic Of Taxation., Richard C.E. Beck

Articles & Chapters

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