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Full-Text Articles in Law
Working With The Section 752 Partnership Liability Allocation Rules (Outline), Jennifer H. Alexander, Andrea M. Whiteway
Working With The Section 752 Partnership Liability Allocation Rules (Outline), Jennifer H. Alexander, Andrea M. Whiteway
William & Mary Annual Tax Conference
No abstract provided.
Negotiating Tax Provisions In Partnership And Llc Agreements, Robert G. Gottlieb, Brian J. O'Connor
Negotiating Tax Provisions In Partnership And Llc Agreements, Robert G. Gottlieb, Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Working With The Section 752 Partnership Liability Allocation Rules (Slides), Jennifer H. Alexander, Andrea M. Whiteway
Working With The Section 752 Partnership Liability Allocation Rules (Slides), Jennifer H. Alexander, Andrea M. Whiteway
William & Mary Annual Tax Conference
No abstract provided.
Integrating Subchapters K And S And Beyond, Walter D. Schwidetzky
Integrating Subchapters K And S And Beyond, Walter D. Schwidetzky
All Faculty Scholarship
This Article builds upon a similar, lengthier effort that I published in the Tax Lawyer in 2009. While there is overlap, this Article contains much new material. Important case law and tax proposals from the House Ways and Means Committee have come out in the interim. Due to space limitations, unlike my Tax Lawyer effort, this Article attempts to avoid prolixity. It assumes the reader has good knowledge of both Subchapters S and K and the tax entity selection process. If you are not that reader, a review of my Tax Lawyer article or Professor Mann's article in this symposium …
Pass-Through Entity Reform: Is A Major Overhaul Necessary?, Walter D. Schwidetzky
Pass-Through Entity Reform: Is A Major Overhaul Necessary?, Walter D. Schwidetzky
All Faculty Scholarship
No abstract provided.
Unwinding The Ceiling Rule, Leigh Osofsky
Unwinding The Ceiling Rule, Leigh Osofsky
Articles
This article closely examines the unwinding of the ceiling rule. Congress and partnership tax experts historically have assumed perfect unwinding of the ceiling rule on liquidation or sale of a partnership interest. However, this assumption glosses over a significantly more complicated reality. This article closely examines the history of section 704(c) and the interaction between the ceiling rule and the rules regarding sales and liquidations of partnership interests to reveal the extent to which the assumption does not hold. By debunking long-held assumptions about the perfect unwinding of the ceiling rule, this article displays that there is no reasonable justification …
When Subchapter S Meets Subchapter C, Martin J. Mcmahon Jr., Daniel L. Simmons
When Subchapter S Meets Subchapter C, Martin J. Mcmahon Jr., Daniel L. Simmons
UF Law Faculty Publications
It is often said that “an S corporation is a corporation that is taxed like a partnership.” This statement is incorrect. An S corporation resembles a partnership only in that it generally does not pay income taxes and its income and losses pass through to the shareholders and retain their character as they pass through. Also, like a partnership, basis adjustments to an S corporation shareholder's stock reflect allocations of income, expense, loss, and distributions. However, no other rules of subchapter K governing partnership taxation apply to S corporations. Most of the rules governing the relationship between an S corporation …