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Full-Text Articles in Law
"Hybrid" Entities And Evolving Issues On Acquisition Structures For Foreign Acquirors, Wm. L. Burke
"Hybrid" Entities And Evolving Issues On Acquisition Structures For Foreign Acquirors, Wm. L. Burke
University of Miami Law Review
No abstract provided.
U.S. Final Transfer Pricing Regulations, John S. Nolan
U.S. Final Transfer Pricing Regulations, John S. Nolan
University of Miami Law Review
No abstract provided.
International Cooperation And Understanding: What's New About The Oecd's Transfer Pricing Guidelines, Frances M. Horner
International Cooperation And Understanding: What's New About The Oecd's Transfer Pricing Guidelines, Frances M. Horner
University of Miami Law Review
No abstract provided.
U.S. Tax Planning For U.S. Companies Doing Business In Latin America, Robert F. Hudson Jr., Gregg D. Lemein
U.S. Tax Planning For U.S. Companies Doing Business In Latin America, Robert F. Hudson Jr., Gregg D. Lemein
University of Miami Inter-American Law Review
No abstract provided.
Section 356(A)(2): A Study Of Uncertainty In Corporate Taxation, William J. Rands
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.
The Service Corporation-- Who Is Taxable On Its Income: Reconciling Assignment Of Income Principles, Section 482, And Section 351, Elliott Manning
The Service Corporation-- Who Is Taxable On Its Income: Reconciling Assignment Of Income Principles, Section 482, And Section 351, Elliott Manning
University of Miami Law Review
In evaluating potential abuses in the creation and operation of service corporations, the courts have been unable to define the proper roles of assignment of income principles and section 482, both of which may under certain conditions require the taxation of such corporations' employee-shareholders, and section 351, which shields certain transfers of income to the corporation. The author, after an analysis of case law and rulings that deal with service and other closely held corporations, proposes a framework in which to harmonize the policies of sections 482 and 351 in light of the assignment of income doctrine.