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Full-Text Articles in Tax Law

Partnership Tax Planning Without Falling Into The Canal (Slides), Andrea M. Whiteway Nov 2012

Partnership Tax Planning Without Falling Into The Canal (Slides), Andrea M. Whiteway

William & Mary Annual Tax Conference

No abstract provided.


Partnership Tax Planning Without Falling Into The Canal (Outline), Andrea M. Whiteway Nov 2012

Partnership Tax Planning Without Falling Into The Canal (Outline), Andrea M. Whiteway

William & Mary Annual Tax Conference

No abstract provided.


Ancillary Joint Ventures And The Unanswered Questions After Revenue Ruling 2004-51 Jul 2012

Ancillary Joint Ventures And The Unanswered Questions After Revenue Ruling 2004-51

Gabriel O Aitsebaomo

Ever since the Internal Revenue Service (the "Service") issued Revenue Ruling 98-15… in which it emphasized "control" as a critical factor in determining whether a tax-exempt hospital that enters into a whole-hospital joint venture with a for-profit entity would continue to maintain its tax-exemption, practitioners and scholars alike have sought guidance from the Service regarding whether such "control" would also be required of an exempt organization that enters into an "ancillary joint venture" with a for-profit entity. In response, the Service issued Revenue Ruling 2004-51 on May 6, 2004.

… In Revenue Ruling 2004-51, the Service enunciated that a tax-exempt …


Limited Liability Entities: State By State Guide To Llcs, Llps And Lps, Bradley Borden, Robert Rhee May 2012

Limited Liability Entities: State By State Guide To Llcs, Llps And Lps, Bradley Borden, Robert Rhee

Robert Rhee

To make your research more efficient Wolters Kluwer Law & Business is combining the former State Limited Liability Company and Partnership Laws and State Limited Partnership Laws title into one new resource entitled Limited Liability Entities: State by State Guide to LLCs, LLPs and LPs. Our new authors are Bradley Borden and Robert Rhee (see About the Authors). Volume 1, the first installment of Limited Liability Entities: State by State Guide to LLCs, LLPs and LPs, provides a comprehensive overview of limited liability entities. It begins with a detailed review of the history and evolution of limited liability entities. It …


The Overlap Of Tax And Financial Aspects Of Real Estate Ventures, Bradley T. Borden Mar 2012

The Overlap Of Tax And Financial Aspects Of Real Estate Ventures, Bradley T. Borden

Bradley T. Borden

This article examines the effect partnership tax law has on financial aspects of real estate ventures. It introduces the relevance of the aggregate and entity views of tax partnerships (i.e., LLCs, LPs, and other partnerships) and demonstrates how those views can greatly affect financial projections for each of the members of a real estate venture. It also demonstrates how financial calculations can vary significantly depending upon how closely analysts track a tax partnership’s allocation method. Finally, the article serves as a primer for tax practitioners who are unfamiliar with the financial tools that are so prevalent in real estate analysis, …


From Allocations To Series Llcs: 2011'S Partnership Tax Articles, Bradley T. Borden Mar 2012

From Allocations To Series Llcs: 2011'S Partnership Tax Articles, Bradley T. Borden

Bradley T. Borden

This article reviews the partnership tax articles published in student-edited journals in 2011. The articles comprise a rich output on timely topics and demonstrate that partnership tax is primed for even more scholarly attention.