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Full-Text Articles in Law

Back To The 1930s? The Shaky Case For Exempting Dividends, Reuven S. Avi-Yonah Dec 2002

Back To The 1930s? The Shaky Case For Exempting Dividends, Reuven S. Avi-Yonah

Articles

This article is based in part on the author’s U.S. Branch Report for Subject I of the 2003 Annual Congress of the International Fiscal Association, to be held next year in Sydney, Australia (forthcoming in Cahiers de droit fiscal international, 2003). He would like to thank Emil Sunley for his helpful comments on that earlier version, and Steve Bank, Michael Barr, David Bradford, Michael Graetz, and David Hasen for comments on this version. Special thanks are due to Yoram Keinan for his meticulous work on the EU regimes (see Appendix). All errors are the author’s. In this report, Prof. Avi-Yonah …


A Whirlwind Tour Of The Internal Revenue Code's At-Risk And Passive Activity Loss Rules, Boris I. Bittker, Martin J. Mcmahon Jr., Lawrence A. Zelenak Jan 2002

A Whirlwind Tour Of The Internal Revenue Code's At-Risk And Passive Activity Loss Rules, Boris I. Bittker, Martin J. Mcmahon Jr., Lawrence A. Zelenak

UF Law Faculty Publications

After providing a glimpse at the historical computation of business operating profit or loss, the authors describe the use of tax shelters as well as legislative responses to them. The authors examine the at-risk and passive activity loss rules, detailing the scope of these rules and offering guidance in the computation of deductions and losses.