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University of Miami Law School

Business Organizations Law

Income tax -- United States

Publication Year

Articles 1 - 2 of 2

Full-Text Articles in Law

Liquidation-Reincorporation: A Sensible Approach Consistent With Congressional Policy, Glenn P. Schwartz Jan 1984

Liquidation-Reincorporation: A Sensible Approach Consistent With Congressional Policy, Glenn P. Schwartz

University of Miami Law Review

No abstract provided.


Section 356(A)(2): A Study Of Uncertainty In Corporate Taxation, William J. Rands Nov 1983

Section 356(A)(2): A Study Of Uncertainty In Corporate Taxation, William J. Rands

University of Miami Law Review

Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorganization to treat any gain recognized as a dividend, if the reorganization "has the effect of the distribution of a dividend." This article examines the conflicting interpretations of this section and offers suggested changes in the law. The article also reviews the performance of all three branches of government in developing tax law.