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Business Organizations Law

William & Mary Law School

Corporate Distributions

Articles 1 - 7 of 7

Full-Text Articles in Law

Corporate Divisions Under Section 355, Mark J. Silverman, Kevin M. Keyes Dec 1989

Corporate Divisions Under Section 355, Mark J. Silverman, Kevin M. Keyes

William & Mary Annual Tax Conference

No abstract provided.


Subchapter S Distributions And Pseudo Distributions: Proposals For Revising The Defective Blend Of Entity And Conduit Concepts, Glenn E. Coven Jan 1987

Subchapter S Distributions And Pseudo Distributions: Proposals For Revising The Defective Blend Of Entity And Conduit Concepts, Glenn E. Coven

Faculty Publications

No abstract provided.


Purchase Price Allocations In Cost Basis Acquisitions: Sections 338 And 1060 Under The 1986 Code, William Rogers, John W. Lee Dec 1986

Purchase Price Allocations In Cost Basis Acquisitions: Sections 338 And 1060 Under The 1986 Code, William Rogers, John W. Lee

William & Mary Annual Tax Conference

No abstract provided.


Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee Apr 1977

Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee

Faculty Publications

Newly issued Proposed Regulations, under Section 355, follow recent decisions allowing horizontal divisions of a single business. In addition, the proposals introduce factors for determining whether a Section 355 transaction is a device for bailing out earnings" Mr. Lee analyzes these and other changes in the Proposed Regulations.


Constructive Cash Distributions, John W. Lee Dec 1976

Constructive Cash Distributions, John W. Lee

William & Mary Annual Tax Conference

No abstract provided.


Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee Jan 1976

Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee

Faculty Publications

The IRS in three Rulings has taken the position that services for the distributing corporation performed through independent contractor could not satisfy the active business requirement test of Section 355. Mr. Lee analyzes the Rulings in light of case law and legislative history that have interpreted the Code's active business test. He concludes that further court tests will be necessary before there can be complete reliance upon active conduct by an independent contractor.


Management Of The Corporation - Distribution Of Cash, Property, Or Stock, William M. Goldstein Dec 1972

Management Of The Corporation - Distribution Of Cash, Property, Or Stock, William M. Goldstein

William & Mary Annual Tax Conference

No abstract provided.