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Full-Text Articles in Business Organizations Law
Initial Impressions Of The Treasury Report On Foundations, Marcus Schoenfeld
Initial Impressions Of The Treasury Report On Foundations, Marcus Schoenfeld
Cleveland State Law Review
Very recently in the United States Treasury Department submitted its study of private foundations to Congress. This is the most recent development in an attempt to delineate the proper role of foundations and their donors in our society, and more particularly their proper tax treatment. Although it is much too soon to predict the effect of the Treasury Report, since Congress itself asked for the study, it is quite likely that some more restrictive legislation will result.
Some Problems In Liquidating Personal Holding Companies, Elliott H. Kajan, Martin C. Spector
Some Problems In Liquidating Personal Holding Companies, Elliott H. Kajan, Martin C. Spector
Cleveland State Law Review
Ordinarily, distributions by a personal holding company qualify for the dividends paid deduction only if they are "dividends" under section 316. However, certain distributions in liquidation may also qualify. These liquidating distributions of a personal holding company are divided into two categories: (1) Distributions to the extent of earnings and profits for the taxable year (computed without regard to capital losses) made in complete liquidation of the corporation occurring within 24 months after the adoption of the plan of liquidation; and (2) distributions in liquidation properly chargeable to earnings and profits accumulated after February 28, 1913.