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Full-Text Articles in Taxation-Federal
Are Frequent Flyer Benefits Really Benefits: An Analysis Of The Frequent Flyer Tax Debate And A New Theory Of Taxability For Frequent Flyer Benefts , Jennifer A. Cunningham
Are Frequent Flyer Benefits Really Benefits: An Analysis Of The Frequent Flyer Tax Debate And A New Theory Of Taxability For Frequent Flyer Benefts , Jennifer A. Cunningham
Cleveland State Law Review
This Note will begin with a brief history of frequent flyer programs and an explanation of how they operate, followed by a closer look at the traditional arguments for nontaxability of mileage earned on personal flights, taxability of mileage earned on business flights for an employer, and proposed theories for valuing the taxable mileage. Next, it will summarize failed attempts by both the courts and the legislature to resolve the issue. After establishing this background, the Note will explore the concept of gross income, particularly as reflected by section 61 of the Internal Revenue Code and interpreted by case law …
Personal Holding Companies And Gross Income, Harvey Mahlig
Personal Holding Companies And Gross Income, Harvey Mahlig
Cleveland State Law Review
There are many small corporations, the ownership o fwhich is in the hands of a family group or a few individuals, which are susceptible to personal holding company rules. These require a careful analysis of stock ownership and gross income. While it may not have been the intention of an individual or of a group to form a personal holding company, circumstances may arise during a year which would qualify the corporation as one. A change in stock ownership, a change in the type of gross income or a change in the amount of gross income could very well transform …
The Western Hemisphere Trading Corporation; In Outline, Samuel Laderman
The Western Hemisphere Trading Corporation; In Outline, Samuel Laderman
Cleveland State Law Review
One of the last frontiers of effective tax reduction exists in the exporting field. This device was specifically created by Congress to enable American corporations trading in foreign countries within the Western Hemisphere to compete with foreign corporations and has been approved by the Commissioner of Internal Revenue. There is no federal law providing for the incorporation of Western Hemisphere Trade Corporations. The corporations are organized under applicable state law and qualify as Western Hemisphere Trade Corporations.