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Full-Text Articles in Law
Opportunities And Pitfalls Under Sections 351 And 721, Craig L. Rascoe, William M. Richardson
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
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
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
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
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
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
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
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
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
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
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
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
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.
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
Faculty Publications
No abstract provided.
Choice Of Entity: C Corporation Versus Pass Through Entities, Gail Levin Richmond
Choice Of Entity: C Corporation Versus Pass Through Entities, Gail Levin Richmond
William & Mary Annual Tax Conference
No abstract provided.