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Articles 1 - 6 of 6
Full-Text Articles in Law
Partnership Allocations: What You Don't Know Can Hurt You, Steven M. Friedman
Partnership Allocations: What You Don't Know Can Hurt You, Steven M. Friedman
William & Mary Annual Tax Conference
No abstract provided.
A Win-Win Proposal For Analyzing Profits-Only Partnership Interests, Brad Borden
A Win-Win Proposal For Analyzing Profits-Only Partnership Interests, Brad Borden
Bradley T. Borden
The proper tax treatment of profits-only partnership interests is an unsolved aspect of tax law. The problem has manifested itself recently in the debate over the proper tax treatment of carried interests, a subset of profits-only partnership interests. Current law taxes holders of profits-only partnership interests based upon the character of income determined at the partnership level. Therefore, a partner who contributes only services to a partnership may be taxed at favorable long-term capital gains rates. One group of commentators recognizes such treatment as inequitable and recommends that at least a portion of partnership income allocated to holders of profits-only …
Slides: Water Needs And Strategies For A Sustainable Future, Shaun Mcgrath
Slides: Water Needs And Strategies For A Sustainable Future, Shaun Mcgrath
Shifting Baselines and New Meridians: Water, Resources, Landscapes, and the Transformation of the American West (Summer Conference, June 4-6)
Presenter: Shaun McGrath, Program Director, Western Governors’ Association
25 slides
Can We Talk?, Don Peters
Can We Talk?, Don Peters
Don Peters
CAN WE TALK: OVERCOMING BARRIERS TO MEDIATING PRIVATE TRANSBORDER COMMERCIAL DISPUTES IN THE AMERICAS Don Peters
This article examines cognitive and cultural barriers creating the comparatively infrequent use of mediation to resolve private, transborder commercial disputes in the Americas. It begins by analyzing the challenges of transborder commercial litigation. It then develops and supports the claim that international arbitration, the most frequently used transborder commercial dispute resolution method , suffers from many of litigation’s disadvantages, including excessive expense and delay, sacrificing outcome control, damaging or ending rather than preserving and improving commercial relationships, and using legalistic, rights based perspectives which …
Five Decades Of Corporation Law - From Conglomeration To Equity Compensation, Richard A. Booth
Five Decades Of Corporation Law - From Conglomeration To Equity Compensation, Richard A. Booth
Working Paper Series
This brief essay recounts developments in corporation law over the last fifty years. It begins with the rise of finance capitalism and the conglomerate corporation which was followed by the emergence of hostile takeovers in the late 1970s and 1980s. One of the key events in this saga was the February 1, 1983 decision by the Delaware Supreme Court in Weinberger v. UOP, Inc. that effectively permitted the at-will elimination of minority stockholders through cashout mergers. Takeovers were also facilitated by two major financial developments: (1) the growth of institutional investors coupled with the growing taste of diversified investors for …
Partnership Tax Allocation And The Internalization Of Tax-Item Transactions, Bradley T. Borden
Partnership Tax Allocation And The Internalization Of Tax-Item Transactions, Bradley T. Borden
South Carolina Law Review
No abstract provided.