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Full-Text Articles in Law

Opportunities And Pitfalls Under Sections 351 And 721, Craig L. Rascoe, William M. Richardson Jan 2007

Opportunities And Pitfalls Under Sections 351 And 721, Craig L. Rascoe, William M. Richardson

William & Mary Annual Tax Conference

No abstract provided.


Partnership Tax Allocation Provisions, Brian J. O'Connor Nov 2006

Partnership Tax Allocation Provisions, Brian J. O'Connor

William & Mary Annual Tax Conference

No abstract provided.


Tax Considerations Of Transfers To And Distributions From The C Or S Corporation, C. Wells Hall Iii Nov 2006

Tax Considerations Of Transfers To And Distributions From The C Or S Corporation, C. Wells Hall Iii

William & Mary Annual Tax Conference

No abstract provided.


Property And Liability Transfers To Partnerships: Built-In Gain Or Loss, Boot, And Disguised Sales, Andrea M. Whiteway Nov 2006

Property And Liability Transfers To Partnerships: Built-In Gain Or Loss, Boot, And Disguised Sales, Andrea M. Whiteway

William & Mary Annual Tax Conference

No abstract provided.


Redemptions Of Partnership Interests And Divisions Of Partnerships, Andrea M. Whiteway Jan 2006

Redemptions Of Partnership Interests And Divisions Of Partnerships, Andrea M. Whiteway

William & Mary Annual Tax Conference

No abstract provided.


Towards Equity And Efficiency In Partnership Allocations, Darryll K. Jones Jan 2006

Towards Equity And Efficiency In Partnership Allocations, Darryll K. Jones

Journal Publications

The primary goal of any tax system is to raise sufficient revenue for government. More precisely, taxation is the means by which government supplies necessary things not available from the private market. Taxation allows society to cure distributional imperfections in the market. It is appropriate, therefore, only to the extent that the market cannot provide goods and services for which there is public demand; if private markets equitably supplied food, shelter, health care, education, and common defense, taxes could be greatly reduced if not completely eliminated. The revenue raising goal is thwarted to the extent the taxing system is either …


Family Limited Partnership Update, Farhad Aghdami Nov 2004

Family Limited Partnership Update, Farhad Aghdami

William & Mary Annual Tax Conference

No abstract provided.


Proposed Regulations On Noncompensatory Options: A Light At The End Of The Tunnel, Walter D. Schwidetzky Jan 2004

Proposed Regulations On Noncompensatory Options: A Light At The End Of The Tunnel, Walter D. Schwidetzky

All Faculty Scholarship

It has become increasingly common for partnerships to issue options. There is a dearth of authority on the federal tax treatment of options to acquire interests in partnerships. In this context, there are two main categories of options, services options and noncompensatory options. Services options, unsurprisingly, are options to acquire partnership interests where the option is received in exchange for services. Noncompensatory options cover the rest of the waterfront. The simplest version of the latter would be partnership analog to normal options found outside the partnership context: the option holder pays the partnership an option premium to acquire an option …


Analyzing The Noncompensatory Partnership Option Proposed Regulations, Dennis A. Diersen Nov 2003

Analyzing The Noncompensatory Partnership Option Proposed Regulations, Dennis A. Diersen

William & Mary Annual Tax Conference

No abstract provided.


Options To Acquire Partnership Interests: Can The Tax Law Keep Pace?, Walter D. Schwidetzky Jan 2003

Options To Acquire Partnership Interests: Can The Tax Law Keep Pace?, Walter D. Schwidetzky

All Faculty Scholarship

It has become increasingly common for partnerships to issue options that give the holder the right to acquire an interest in the partnership for a set price. The holder of the option will exercise it if he feels that the partnership interest to be acquired is worth more than the exercise price. There is a dearth of authority on the federal tax treatment of option transactions, and the Service has recently asked for guidance from the tax bar as to what approach it should take. This article focuses on one piece of the partnership option puzzle, options to acquire partnership …


Selected Tax Issues For Pass-Through Entities, Charles H. Egerton, Samuel P. Starr Dec 1996

Selected Tax Issues For Pass-Through Entities, Charles H. Egerton, Samuel P. Starr

William & Mary Annual Tax Conference

No abstract provided.


All In The Family (Partnership), Charles H. Egerton Dec 1996

All In The Family (Partnership), Charles H. Egerton

William & Mary Annual Tax Conference

No abstract provided.


A Practical Guide To The Tax Consequences Of Disposing Of A Partnership (Or Llc) Business, Richard M. Lipton, John T. Thomas Dec 1996

A Practical Guide To The Tax Consequences Of Disposing Of A Partnership (Or Llc) Business, Richard M. Lipton, John T. Thomas

William & Mary Annual Tax Conference

No abstract provided.


Case Studies: Small Professional Services Organization And Large Professional Services Organization, L. Michael Gracik Jr. Dec 1995

Case Studies: Small Professional Services Organization And Large Professional Services Organization, L. Michael Gracik Jr.

William & Mary Annual Tax Conference

No abstract provided.


Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin Dec 1995

Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin

William & Mary Annual Tax Conference

No abstract provided.


Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant Dec 1995

Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant

William & Mary Annual Tax Conference

No abstract provided.


Meeting With Irs Regarding Partnership Issues In Developing Section 1017 Regulations, Blake D. Rubin Dec 1995

Meeting With Irs Regarding Partnership Issues In Developing Section 1017 Regulations, Blake D. Rubin

William & Mary Annual Tax Conference

No abstract provided.


Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin Dec 1995

Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin

William & Mary Annual Tax Conference

No abstract provided.


Case Studies: Scenarios Nos. 1, 2 & 3, Thomas R. Frantz Dec 1995

Case Studies: Scenarios Nos. 1, 2 & 3, Thomas R. Frantz

William & Mary Annual Tax Conference

No abstract provided.


Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon Dec 1994

Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon

William & Mary Annual Tax Conference

No abstract provided.


Planning For The Termination Of An Interest In A Partnership - Withdrawals, Distributions And Other Exit Strategies, Michael G. Frankel Dec 1994

Planning For The Termination Of An Interest In A Partnership - Withdrawals, Distributions And Other Exit Strategies, Michael G. Frankel

William & Mary Annual Tax Conference

No abstract provided.


Federal Taxation On Disposition Of Partnership Interests, Richard A. Shaw Dec 1994

Federal Taxation On Disposition Of Partnership Interests, Richard A. Shaw

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments Affecting Real Estate And Partnerships, Stefan F. Tucker Dec 1992

Recent Developments Affecting Real Estate And Partnerships, Stefan F. Tucker

William & Mary Annual Tax Conference

No abstract provided.


Using Partnerships As Acquisition Vehicles, Mark J. Silverman Dec 1990

Using Partnerships As Acquisition Vehicles, Mark J. Silverman

William & Mary Annual Tax Conference

No abstract provided.


Allocating Partnership Liabilities Under The New Section 752 Regulations, William F. Nelson Dec 1989

Allocating Partnership Liabilities Under The New Section 752 Regulations, William F. Nelson

William & Mary Annual Tax Conference

No abstract provided.


Planning Considerations For Like-Kind Exchanges Involving Partnerships, Joseph G. Howe Iii Dec 1989

Planning Considerations For Like-Kind Exchanges Involving Partnerships, Joseph G. Howe Iii

William & Mary Annual Tax Conference

No abstract provided.


Termination Of Partnerships And Of Partnership Interests, Louis A. Mezzullo Dec 1988

Termination Of Partnerships And Of Partnership Interests, Louis A. Mezzullo

William & Mary Annual Tax Conference

No abstract provided.


Partnership Operations And Distributions, Steven M. Friedman Dec 1988

Partnership Operations And Distributions, Steven M. Friedman

William & Mary Annual Tax Conference

No abstract provided.


Entity Classification And Integration: Publicly Traded Partnerships, Personal Service Corporations And The Tax Legislative Process, John W. Lee Jul 1988

Entity Classification And Integration: Publicly Traded Partnerships, Personal Service Corporations And The Tax Legislative Process, John W. Lee

Faculty Publications

No abstract provided.


Choice Of Entity: C Corporation Versus Pass Through Entities, Gail Levin Richmond Dec 1987

Choice Of Entity: C Corporation Versus Pass Through Entities, Gail Levin Richmond

William & Mary Annual Tax Conference

No abstract provided.