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A Different Look At The Taxation Of Corporate Distribution And Shareholder Gain, Charles O'Kelley
A Different Look At The Taxation Of Corporate Distribution And Shareholder Gain, Charles O'Kelley
Faculty Articles
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code which has fostered a seemingly never-ending yet never-successful attempt by the Courts and Congress to design a coherent, non-discriminatory regime. In this article, Professor O'Kelley sets forth a proposal for a logical system for treating corporate distributions to shareholders which would strengthen the double tax scheme, and eliminate its present loopholes.