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Full-Text Articles in Law
Dynamic Economic Analyses Of Selected Provisions Of Corporate Law: The Absolute Delegation Rule, Disclosure Of Intermediate Estimates And Ipo Pricing, Royce De R. Barondes
Dynamic Economic Analyses Of Selected Provisions Of Corporate Law: The Absolute Delegation Rule, Disclosure Of Intermediate Estimates And Ipo Pricing, Royce De R. Barondes
Faculty Publications
This Article examines three separate aspects of the relationships between corporations and their securityholders from a dynamic economic perspective: (i) the feasibility of permitting shareholders to participate in the management of their corporations through the exercise of voting rights, (ii) Rule 3b-6, the safe harbor for projections (the Safe Harbor)8 under the Securities Exchange Act of 1934 (the 1934 Act),9 and (iii) the extraordinary returns available from investing in initial public offerings (IPO's). Three particular dynamic aspects are implicated in these situations.
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 2), John W. Lee
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 2), John W. Lee
Faculty Publications
In this article, Professor Lee charts two alternative methods for implementing an aggregate solution to the problem of partnership profits share for services. The functional, or judicial, method is to handle (1) the exchange of partner-capacity services for a profit share subject to the risk f the venture with the Culbertson "common law relation of partnership," nonrealization event doctrine, implicitly contemplated by the 1984 legislative history to section 707(a)(2), (2) the classic Diamond transitory partner with a substance-over-form rule or step-transaction rule, and (3) a sale of the partnership interest in circumstances that would result in ordinary income in a …
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 1), John W. Lee
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 1), John W. Lee
Faculty Publications
In this article, Lee charts two alternative methods for implementing an aggregate solution to the problem of partnership profits share exchanged for services. The functional, or judicial, method, he explains, is to handle (1) the exchange of partner-capacity services for a profit share subject to the risk of the venture with the Culbertson "common law relation of partnership," nonrealization event doctrine, implicitly contemplated by the 1984 legislative history to section 707(a)(2); (2) the classic Diamond transitory partner with a substance-over-form rule or step-transaction rule; and (3) a sale of the partnership interest in circumstances that would result in ordinary income …