Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 7 of 7
Full-Text Articles in Law
Corporate Divisions Under Section 355, Mark J. Silverman, Kevin M. Keyes
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
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
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
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
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
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
Management Of The Corporation - Distribution Of Cash, Property, Or Stock, William M. Goldstein
William & Mary Annual Tax Conference
No abstract provided.