Law Commons^™

Federal Income Taxation-Disallowance Of Surtax Exemption To Brother-Sister Corporations-Stock Ownership Test Under Sections 1551 And 1563 - Fairfax Auto Parts Of N. Va., Inc. V. Commissioner, James E. Skeen

BYU Law Review

No abstract provided.

Klein: Policy Analysis Of The Federal Income Tax, J. Clifton Fleming Jr.

BYU Law Review

No abstract provided.

Germany - The New Corporation Tax System, Hugh Ault

Hugh J. Ault

No abstract provided.

Taxes--Constitutional Law--Nondiscriminatory Ad Valorem Tax Not Prohibited By Import-Export Clause, Michael F. Swick

Mercer Law Review

In Michelin Tire Corp. v. Wages the United States Supreme Court held that the assessment by the tax commissioners and tax assessors of Gwinnett County, Georgia, of a nondiscriminatory ad valorem property tax against petitioner's inventory of imported tires maintained at its wholesale distribution warehouse was not within the prohibition of the Import- Export Clause of the Constitution.

The Tax Reform Act Of 1975 And The Foreign Tax Area, Richard S. Lehman

University of Miami Inter-American Law Review

No abstract provided.

Federal Taxation--Credit Allowed For Foreign Social Security Payments, Ronald M. Mack

Mercer Law Review

In Revenue Ruling 69-338 the Internal Revenue Service held that certain compulsory contributions levied on the salary of a U.S. citizen employee under article 66 of the Venezuelan social security law were "an income tax which is creditable within the meaning of section 901 of the Code."

Section 901 requires that in order for a foreign tax to be creditable against U.S. income tax, it must be an income tax, a war profit tax, or an excess profits tax. Section 903 expands the concept by making certain taxes imposed in lieu of income taxes also creditable against U.S. income tax.

Federal Taxation Of Corporate Unifications: A Review Of Legislative Policy, Ulysses S. Crockett Jr.

Duquesne Law Review

Throughout most of the twentieth century, federal tax laws have permitted nonrecognition of gain in specified corporate reorganizations. This article traces the legislative history of the nonrecognition provisions and discusses some of their resulting economic effects. The author concludes that present tax treatment of mergers and other corporate unifications needs congressional reexamination.

Reconciling Business Purpose With Bail-Out Prevention: Federal Tax Policy And Corporate Divisions, Stephen B. Cohen

Georgetown Law Faculty Publications and Other Works

Corporate divisions-spin-offs, split-offs, and split-ups-unfortunately pose a more complex problem than Senator Humphrey's childlike vision would lead one to believe: the reconciliation of competing goals of maximizing business flexibility and minimizing tax avoidance. It is widely believed that divisions are essential to business planning; thus, tax-free treatment promotes business flexibility. Yet, an untaxed division may allow tax avoidance through "bail-out" of corporate earnings and profits at capital gain rates.

Puttkammer V. Commissioner Of Internal Revenue, Robert English

Maryland Journal of International Law

No abstract provided.

The Contribution Limitations For I.R.C. 403(B) Tax Sheltered Annuities After Erisa, Kevin E. Irwin

Cleveland State Law Review

This Comment will consider the contribution limitations imposed upon section 403(b) annuities before ERISA and then proceed to examine the present contribution limitations in depth. A grasp of the mechanics of calculating an employee's contribution limitations is indispensable to an understanding of the concepts involved. Examples will therefore be used throughout this Comment to illustrate the determination of these limitations.

Real Estate Tax Shelters: How To Tell A Good Deal From A Bad Deal, Marvin Kelner

Cleveland State Law Review

That the purpose of these comments is to impart basic knowledge to the legal or financial advisor who is asked to render advice to his (or her) client (who is assumed to be in at least the 50 percent marginal income tax bracket) on whether to invest in a particular real estate tax shelter syndication. Hopefully, this article will enable such an advisor to give an informed opinion regarding the investment without holding himself out as an expert in real estate tax shelters. The following are my views with respect to important standards against which one can test the desirability …

The Tax Consequences Of Inter Vivos Charitable Contributions After December 31, 1969 Under Section 170, Olin R. Melchionna Jr.

University of Richmond Law Review

To give and live to give again has always been the American way. Traditionally, Americans contribute to those charitable institutions and associations which effectuate their benevolent, philanthropic desires. Many individuals believe the funding of charitable institutions should be primarily by direct contributions from the private sector as opposed to federal and state government subsidies. This view is supported by the federal income, I gift and estate tax deductions.

The Ab (Abc) And Ba Transactions: An Economic And Tax Analysis Of Reserved And Carved Out Income Interests, Kenneth F. Joyce, Louis A. Del Cotto

Journal Articles

No abstract provided.

United States V. Foster Lumber Co.: Net Operating Losses And Capital Gains - You Can Have Two, But You Only Get One, Robert M. Wilson

Cleveland State Law Review

In 1974 a conflict development among circuit courts over the application of the net operating loss carryback provisions of the Internal Revenue Code to years in which a corporate taxpayer enjoyed the benefit of the "alternative" method for the computation of the capital gains tax. In November 1976, the United States Supreme Court resolved the conflict in favor of the Internal Revenue Service in United States v. Foster Lumber Co. This Case Comment will analyze Foster Lumber, as well as some of the earlier conflicting decisions, in an effort to determine if the Supreme Court has effectively resolved the problem

Limiting Religious Tax Exemptions: When Should The Church Render Unto Caesar?, Stephen Schwarz

Faculty Scholarship

No abstract provided.

The Federal Taxation Of Options Investors: An Examination Of Sections 1091, 1233 And 1234 For Their Implications And Tax-Planning Potential, John A. Berry

Loyola University Chicago Law Journal

No abstract provided.

[Commentators And Translators] The German Corporation Tax Reform Law 1977, Hugh Ault, Albert Rädler

Hugh J. Ault

Translation of Körperschaftsteuerreformgesetz 1977. Frankfurt: Alfred Metzner, 1976.