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Full-Text Articles in Taxation-Federal
Ogiony V. Commissioner, 617 F.2d 14 (2d Cir. 1980), Vincent A. Sable
Ogiony V. Commissioner, 617 F.2d 14 (2d Cir. 1980), Vincent A. Sable
Florida State University Law Review
Taxation-DISREGARDING THE CORPORATE ENTITY-PARTNERS UNABLE TO IGNORE EXISTENCE OF CORPORATION USED FOR FINANCING PURPOSES
Corporate Distributions And The Income Tax: A Consideration Of The Inconsistency Between Subchapter C And Its Underlying Policy, Charles O'Kelley
Corporate Distributions And The Income Tax: A Consideration Of The Inconsistency Between Subchapter C And Its Underlying Policy, Charles O'Kelley
Faculty Articles
The issue of whether the sale of shares to an issuer shall be treated as a dividend or as received in exchange for a capital asset has troubled Congress, courts, and commentators since the Revenue Act of 1913. If a corporation redeems some of its shares or distributes all of its assets in complete liquidation, the transaction is generally described as having the characteristics of a divided to the extent the distribution is ‘out of earnings and profits' and the characteristics of a sale to the extent that it terminates the equity interest of the redeemed party. In light of …
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Hugh J. Ault
Introduction à la Fiscalité Internationale Américaine, translated by Arthur Young and Company, 1982.
Subpart F À La Française [French Attitude To Tax Havens], Hugh Ault, Philip Kaplan
Subpart F À La Française [French Attitude To Tax Havens], Hugh Ault, Philip Kaplan
Hugh J. Ault
No abstract provided.
Germany: Developments Concerning 'Thin Capitalization', Hugh Ault, Philip Kaplan
Germany: Developments Concerning 'Thin Capitalization', Hugh Ault, Philip Kaplan
Hugh J. Ault
No abstract provided.
Belgium: Entity Classification, Hugh Ault, Philip Kaplan
Belgium: Entity Classification, Hugh Ault, Philip Kaplan
Hugh J. Ault
No abstract provided.