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Full-Text Articles in Law
Business Activities Of Tax-Exempts And Affiliates, Jo Ann Blair
Business Activities Of Tax-Exempts And Affiliates, Jo Ann Blair
William & Mary Annual Tax Conference
No abstract provided.
1986 Tax Reform Act: Alternative Minimum Tax On Corporations (Section 55, Irc And Section 701(A) Act), Paul Broderick
1986 Tax Reform Act: Alternative Minimum Tax On Corporations (Section 55, Irc And Section 701(A) Act), Paul Broderick
William & Mary Annual Tax Conference
No abstract provided.
1986 Tax Reform Act (Tra) Limitations On Net Operating Loss Carryforwards (Sections 382 And 383, Irc And Section 621, Act), Paul Broderick
1986 Tax Reform Act (Tra) Limitations On Net Operating Loss Carryforwards (Sections 382 And 383, Irc And Section 621, Act), Paul Broderick
William & Mary Annual Tax Conference
No abstract provided.
Wilderness And Natural Area Preservation In The United States: A Survey Of National Laws, George W. Pring, Stephen Miller
Wilderness And Natural Area Preservation In The United States: A Survey Of National Laws, George W. Pring, Stephen Miller
Proceedings of the Sino-American Conference on Environmental Law (August 16)
32 pages.
Contains 5 pages of endnotes.
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 Infield Fly Rule And The Internal Revenue Code: An Even Further Aside, Mark W. Cochran
The Infield Fly Rule And The Internal Revenue Code: An Even Further Aside, Mark W. Cochran
Faculty Articles
Baseball’s infield fly rule and certain provisions of the Internal Revenue Code are similar. The purpose of the infield fly rule is to prevent the defense from making a double play by subterfuge, at a time when the offense is helpless to prevent it.
In baseball, as in life, fairness is an elusive concept that defies precise definition. Considering the infield fly rule, the “unfairness” derives from the infielder’s ability to manipulate a situation without incurring any risk. Federal tax law, like the rules of baseball, recognizes and responds to the “manipulation without risk” phenomenon. Section 267 of the Internal …