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Articles 61 - 90 of 139
Full-Text Articles in Law
Ethical Issues In Tax Practice, Robert I. Brauer, James P. Holden
Ethical Issues In Tax Practice, Robert I. Brauer, James P. Holden
William & Mary Annual Tax Conference
No abstract provided.
Integrating Qualified Plan Distributions Into The Overall Financial And Estate Plan, Bruce J. Temkin
Integrating Qualified Plan Distributions Into The Overall Financial And Estate Plan, Bruce J. Temkin
William & Mary Annual Tax Conference
No abstract provided.
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
William & Mary Annual Tax Conference
No abstract provided.
Meeting With Irs Regarding Partnership Issues In Developing Section 1017 Regulations, Blake D. Rubin
Meeting With Irs Regarding Partnership Issues In Developing Section 1017 Regulations, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
William & Mary Annual Tax Conference
No abstract provided.
Focus On Capitalization V. Deductibility - Environmental Remediation, Stefan F. Tucker
Focus On Capitalization V. Deductibility - Environmental Remediation, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
The Tax Treatment Of Environmental Cleanup Costs, Blake D. Rubin, Seth Green, Katherine P. Rosefsky
The Tax Treatment Of Environmental Cleanup Costs, Blake D. Rubin, Seth Green, Katherine P. Rosefsky
William & Mary Annual Tax Conference
No abstract provided.
Planning For The Taxable Disposition Of Overleveraged Property, Blake D. Rubin
Planning For The Taxable Disposition Of Overleveraged Property, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
The Like Kind Exchange: Everything You Need To Know, Whether Or Not You Wanted To Ask, Stefan F. Tucker
The Like Kind Exchange: Everything You Need To Know, Whether Or Not You Wanted To Ask, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
The Limited Liability Company Experiment: Unlimited Flexibility, Uncertain Role, Wayne M. Gazur
The Limited Liability Company Experiment: Unlimited Flexibility, Uncertain Role, Wayne M. Gazur
Publications
No abstract provided.
Taxation Of Damages After Schleier - Where Are We And Where Do We Go From Here?, Douglas A. Kahn
Taxation Of Damages After Schleier - Where Are We And Where Do We Go From Here?, Douglas A. Kahn
Articles
This article will examine the reasoning of the Schleier decision and speculate as to how taxation of pre-1996 damages will likely apply in light of Schleier. First, the article will set forth a very brief history of the judicial and administrative constructions of the statutory exclusion, and explore tax policy justifications for providing an exclusion from gross income for certain damages. These latter two items (set forth in Parts II and III of this article) are areas that have been extensively addressed previously by several commentators, including the author of this article.' The reason for exploring tax policy issues is …
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 …
Section 338 And Its Foolish Consistency Rules - The Hobgoblin Of Little Minds, Douglas A. Kahn
Section 338 And Its Foolish Consistency Rules - The Hobgoblin Of Little Minds, Douglas A. Kahn
Articles
The purposes of this Article are to examine whether there is any longer a reason for concern because a target corporation can choose selected assets for nonrecognition and to what extent the 1994 regulations properly deal with potentially abusive circumventions of tax goals. Before examining the current status of the consistency requirements, the historical background that led to the adoption of Section 338 and the operation of the section is discussed. The historical background includes: the judicially created Kimbell-Diamond rule, the codification and modification of that rule by the old version of Section 334(b)(2), the operation of the old version …
Redemptions Incident To Divorce: Reconciling Section 1041 And General Tax Principles, Leandra Lederman
Redemptions Incident To Divorce: Reconciling Section 1041 And General Tax Principles, Leandra Lederman
Articles by Maurer Faculty
No abstract provided.
Miscellaneous Revenue Issues: Hearings Before The Subcommittee On Select Revenue Measures Of The Committee On Ways And Means, House Of Representatives, One Hundred Third Congress, First Session, Charles B. Rangel, Mel Hancock, Stefan F. Tucker, B. Wyckliffe Pattishall Jr., Howard J. Levine, John W. Lee
Miscellaneous Revenue Issues: Hearings Before The Subcommittee On Select Revenue Measures Of The Committee On Ways And Means, House Of Representatives, One Hundred Third Congress, First Session, Charles B. Rangel, Mel Hancock, Stefan F. Tucker, B. Wyckliffe Pattishall Jr., Howard J. Levine, John W. Lee
Congressional Testimony
No abstract provided.
Intangible Asset Depreciation: Newark And Section 197, Kenneth W. Gideon
Intangible Asset Depreciation: Newark And Section 197, Kenneth W. Gideon
William & Mary Annual Tax Conference
No abstract provided.
Compensatory And Punitive Damages For A Personal Injury: To Tax Or Not To Tax, Douglas A. Kahn
Compensatory And Punitive Damages For A Personal Injury: To Tax Or Not To Tax, Douglas A. Kahn
Articles
Since the adoption in 1919 of the Revenue Act of 1918, damages received on account of personal injuries or sickness have been excluded by statute from gross income.1 This exclusion, which does not apply to reimbursements for medical expenses for which the taxpayer was previously allowed a tax deduction,2 is presently set forth in section 104(a)(2). One might expect that a provision having recently attained the ripe age of 75 years without change in its basic language would have a settled meaning. However, recent litigation under section 104(a)(2) bristles with unsettled issues. Does the exclusion apply to punitive damages? To …
Tax Policy And Panda Bears, Douglas A. Kahn, Jeffrey S. Lehman
Tax Policy And Panda Bears, Douglas A. Kahn, Jeffrey S. Lehman
Articles
In this article. Professors Kahn and Lehman argue that the concept of tax expenditure is flawed as a tool for measuring the propriety of tax provisions. It assumes the existence of on true and correct standard of federal income taxation that applies to all circumstances. To make that a assumption, the proponents of the concept implicitly make a particular moral claim about the relative importance of a wide range of values, including efficiency, consumption/savings neutrality, privacy, distributional equity, administrabiliy, charity, and pragmatism. They then measure a tax provision's "normalcy" exclusively by how it conforms to their Platonic concept of income. …
Tax Expenditure Budgets: A Critical View, Douglas A. Kahn, Jeffrey S. Lehman
Tax Expenditure Budgets: A Critical View, Douglas A. Kahn, Jeffrey S. Lehman
Articles
During the past few months, Tax Notes has featured an extended discussion about the "normalcy" (or lack thereof) of accelerated depreciation. Two contributions to that discussion came from Professor Calvin Johnson of the University of Texas Law School, who disagreed with certain aspects of an article that Professor Kahn wrote in 1979. And the debate shows no sign of slowing down. The interchange over the details of accelerated depreciation offers a useful backdrop against which to consider a more general issue: the intellectual coherence of the tax expenditure budgets. The larger concept of tax expenditures was what motivated Kahn to …
Planning Opportunities After Chapter 14 (Section 2701 And 2702), Frederic A. Nicholson
Planning Opportunities After Chapter 14 (Section 2701 And 2702), Frederic A. Nicholson
William & Mary Annual Tax Conference
No abstract provided.
Section 382: Net Operating Loss Carryovers In Corporate Acquisitions, Peter L. Faber
Section 382: Net Operating Loss Carryovers In Corporate Acquisitions, Peter L. Faber
William & Mary Annual Tax Conference
No abstract provided.
Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner
Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner
William & Mary Annual Tax Conference
No abstract provided.
Current Issues In Estate Planning Featuring The Replacement Of Section 2036(C), Ronald D. Aucutt
Current Issues In Estate Planning Featuring The Replacement Of Section 2036(C), Ronald D. Aucutt
William & Mary Annual Tax Conference
No abstract provided.
The Affiliated Management Group And Code § 414(M), Robert M. Reed
The Affiliated Management Group And Code § 414(M), Robert M. Reed
William & Mary Annual Tax Conference
No abstract provided.
Altruism In Nonprofit Organizations, Rob Atkinson
Altruism In Nonprofit Organizations, Rob Atkinson
Scholarly Publications
No abstract provided.
Chaos In Wonderland: A Review Of The Regulations Issued Under Irc Section 89, Rebecca J. Miller
Chaos In Wonderland: A Review Of The Regulations Issued Under Irc Section 89, Rebecca J. Miller
William & Mary Annual Tax Conference
No abstract provided.
Corporate Divisions Under Section 355, Mark J. Silverman, Kevin M. Keyes
Corporate Divisions Under Section 355, Mark J. Silverman, Kevin M. Keyes
William & Mary Annual Tax Conference
No abstract provided.
Section 2036(C), Jere D. Mcgaffey
Section 2036(C), Jere D. Mcgaffey
William & Mary Annual Tax Conference
No abstract provided.
Tax Aspects Of Divorce And Separation: Alimony, Child Support And Property Transfers, Robert E. Lee
Tax Aspects Of Divorce And Separation: Alimony, Child Support And Property Transfers, Robert E. Lee
William & Mary Annual Tax Conference
No abstract provided.