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The Social Boundaries Of Corporate Taxation, Sloan G. Speck
The Social Boundaries Of Corporate Taxation, Sloan G. Speck
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Historically, the tax law distinction between corporate and conduit treatment drew primarily on doctrinal understandings, treating state-law corporations as corporate for tax purposes and classifying unincorporated legal entities based on their resemblance to conventional state-law corporations. More recently, commentators and Treasury have abandoned these doctrinal touchstones in favor of efficiency, broadly construed, as the guiding principle in determining an entity’s tax classification. This Article argues that, while important, efficiency considerations should not function as the sole arbiter of the boundary between corporate and conduit tax treatment. First, classical corporate taxation is, in many ways, deeply embedded within a larger network …
The Limited Liability Company Experiment: Unlimited Flexibility, Uncertain Role, Wayne M. Gazur
The Limited Liability Company Experiment: Unlimited Flexibility, Uncertain Role, Wayne M. Gazur
Publications
No abstract provided.