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Articles 1 - 5 of 5
Full-Text Articles in Tax Law
How The Massachusetts Supreme Judicial Court Should Interpret Wynne, Michael S. Knoll, Ruth Mason
How The Massachusetts Supreme Judicial Court Should Interpret Wynne, Michael S. Knoll, Ruth Mason
All Faculty Scholarship
In this special report, Knoll and Mason discuss how the Massachusetts Supreme Judicial Court should apply Wynne when it hears on remand First Marblehead v. Commissioner of Revenue. The authors conclude that when it originally heard the case, the Massachusetts court mistakenly considered, as part of its internal consistency analysis, whether Gate Holdings Inc. experienced double state taxation. As developed by the U.S. Supreme Court and most recently applied in Wynne, the internal consistency test is not concerned with actual double taxation that may arise from the interaction of different states’ laws. Rather, the test is designed to determine …
Let's Make A Deal! Business Succession Planning, John M. Olivieri, Stefan F. Tucker
Let's Make A Deal! Business Succession Planning, John M. Olivieri, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Simple Substantial Economic Effect Regulatory Compliance, David Randall Jenkins
Simple Substantial Economic Effect Regulatory Compliance, David Randall Jenkins
David Randall Jenkins
The Internal Revenue Service considers Section 704(b)’s substantial economic effect regulations among the most complex. This course teaches the Treasury Regulations enable simple compliance through (Per Capita: Balances: Ratios) capital account accounting method truncated transitivity, economic effect equivalence, and substantiality’s conclusive presumption. The partnership special allocations public policy mandate is made clear thereby: encourage going concern productivity while discouraging its abandonment.
G8 Principles: Identifying The Anonymous, Max Biedermann
G8 Principles: Identifying The Anonymous, Max Biedermann
Brigham Young University International Law & Management Review
No abstract provided.
Building Prohibited Transaction Chinese Walls For Retirement Plan Investment Structures, David Randall Jenkins
Building Prohibited Transaction Chinese Walls For Retirement Plan Investment Structures, David Randall Jenkins
David Randall Jenkins
Knowing how to structure client career revising strategies by funding business ventures with extant retirement plan assets is an important transaction structuring tool for today’s professional. Enabling both account holder compensation and personal guaranties of enterprise debt appears to be a formidable undertaking in today’s decisional law climate. The key to empowering such client objectives lies in understanding how retirement plan management and investment risk diversification policy compliance, together with properly invoked plan asset rule exceptions, erect Prohibited Transaction Chinese Walls and enable (self-dealing activity: incidental benefit) transitions.