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Articles 121 - 147 of 147
Full-Text Articles in Law
Bearing Witness: The Art And Science Of Human Rights Fact-Finding, Diane Orentlicher
Bearing Witness: The Art And Science Of Human Rights Fact-Finding, Diane Orentlicher
Articles in Law Reviews & Other Academic Journals
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.
Choice Of Entity: Pass Through Entities, John W. Lee
Choice Of Entity: Pass Through Entities, John W. Lee
William & Mary Annual Tax Conference
No abstract provided.
An Aggregate Approach To Indirect Exchanges Of Partnership Interests: Reconciling Section 1031 And Subchapter K, Karen C. Burke
An Aggregate Approach To Indirect Exchanges Of Partnership Interests: Reconciling Section 1031 And Subchapter K, Karen C. Burke
UF Law Faculty Publications
This article examines indirect exchanges of partnership interests in light of the distinctive continuity-of-investment principles of section 1031 and Subchapter K of the Internal Revenue Code. Part II of the article focuses on the failure of judicial responses and alternative approaches prior to the 1984 Act to prevent the potential abuses of direct exchanges of partnership interests. Part III examines section 1031(a)(2)(D) against the background of two recent decisions by the United States Court of Appeals for the Ninth Circuit concerning successive tax-free exchanges. Part IV focuses on planning techniques involving like-kind exchanges coupled with partnership contributions and distributions. Part …
The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom
The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom
William & Mary Annual Tax Conference
No abstract provided.
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Faculty Publications
No abstract provided.
The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven
The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven
William & Mary Annual Tax Conference
No abstract provided.
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Articles
If several persons wish to join together in a common enterprise in order to pool their capital or labor or some of each, they may choose among a variety of available organizational structures that will serve that purpose. The most common entity forms are partnerships (including joint ventures), corporations, and trusts. While, in its typical structure, each of those entity forms has its own distinct characteristics, the structure of such organizations often is modified by agreement so as to adopt attributes of another type of entity. Because of this, the substantive distinction between entity types is blurred.
Death Or Retirement Of A Partner, Stefan F. Tucker
Death Or Retirement Of A Partner, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Income And Estate Tax Planning With Subchapter S Corporations, Robert J. Hipple, Barbara C. Hipple
Income And Estate Tax Planning With Subchapter S Corporations, Robert J. Hipple, Barbara C. Hipple
William & Mary Annual Tax Conference
No abstract provided.
Partnerships And At Risk Problems, Stefan F. Tucker
Partnerships And At Risk Problems, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Optional Adjustments To Basis Of Partnership Property On Transfer Of Partnership Interests, Donald J. Weidner
Optional Adjustments To Basis Of Partnership Property On Transfer Of Partnership Interests, Donald J. Weidner
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entities For Holding Real Estate: Partnerships, Alan J.B. Aronsohn
Choice Of Entities For Holding Real Estate: Partnerships, Alan J.B. Aronsohn
William & Mary Annual Tax Conference
No abstract provided.
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
Faculty Publications
No abstract provided.
Collapsible Partnerships, Michael S. Applebaum
Collapsible Partnerships, Michael S. Applebaum
William & Mary Annual Tax Conference
No abstract provided.
Compensating The Promoter-General Partner, Martin B. Cowan
Compensating The Promoter-General Partner, Martin B. Cowan
William & Mary Annual Tax Conference
No abstract provided.
Partnership Allocations, Donald J. Weidner
Partnership Allocations, Donald J. Weidner
William & Mary Annual Tax Conference
No abstract provided.
Pre-Operating Expenses And Section 174: Will "Snow" Fall?, John W. Lee
Pre-Operating Expenses And Section 174: Will "Snow" Fall?, John W. Lee
Faculty Publications
No abstract provided.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Faculty Publications
In the recent Rodman case, the Tax Court has held that a partner newly admitted near year-end must report his share of the full year's partnership profits. Messrs. Lee and Parker analyze the status of retroactive partnership allocations in view of Rodman, the first decision to expressly sanction retroactive allocations of income (and implicitly of losses) to new partners, and reallocations under Section 704.
Comparison Of Major Tax And Legal Advantages Of Operating In An Unincorporated Form, Douglas A. Kahn
Comparison Of Major Tax And Legal Advantages Of Operating In An Unincorporated Form, Douglas A. Kahn
Book Chapters
As an introduction to the subject of this conference, several topics will be discussed. First, the tax and non-tax consequences of conducting business in a partnership form will be examined and compared with the consequences of doing business in a corporate form. The principle concern of this paper, however, is to examine the tax consequences of transferring property to a corporation, whether such transfer is made at the time the corporation is organized or at some subsequent date.
Book Review. Cases On Business Organization By R. Magill And R. P. Hamilton, Robert C. Brown
Book Review. Cases On Business Organization By R. Magill And R. P. Hamilton, Robert C. Brown
Articles by Maurer Faculty
No abstract provided.
Partnership Entity And Tenancy In Partnership: The Struggle For A Definition, Joseph H. Drake
Partnership Entity And Tenancy In Partnership: The Struggle For A Definition, Joseph H. Drake
Articles
PARTNERSHIP is a legal entity formed by the association of two or more persons. This definition of a partnership as a person or entity represents what may be characterized as a generally accepted theory among American jurists at the time of its publication in 1893. But a later definition says: "A partnership is an association of two more persons." "A partner is co-owner with his partners of specific partnership property holding as a tenant in partnership." The second definition shows that the Commissioners on Uniform State Laws have rejected the entity theory and coined a new term to describe partnership …