Open Access. Powered by Scholars. Published by Universities.®
- Discipline
- Keyword
-
- TEFRA (3)
- IRS (2)
- IRS code (2)
- Business tax (1)
- C Corporations (1)
-
- Corporate assets (1)
- Corporate stock (1)
- Corporate stock acquisitions (1)
- Corporate tax (1)
- ERTA (1)
- Employee retirement income security act (1)
- Estate (1)
- Family corporation (1)
- Federal income tax (1)
- Fiduciary income tax (1)
- Gregory v Helvering (1)
- IRA (1)
- ITC (1)
- Income tax (1)
- Partnership (1)
- Pension (1)
- S corporation (1)
- Step-transaction (1)
- Subchapter C (1)
- Successor-in-interest (1)
- Tax equity (1)
- Technical Amendments Act (1)
Articles 1 - 7 of 7
Full-Text Articles in Law
Federal Income Tax Developments: 1982, Merlin G. Briner
Federal Income Tax Developments: 1982, Merlin G. Briner
Akron Tax Journal
This article discusses federal income tax developments in 1982, including relevant Supreme Court cases, oil and gas, tax shelters, deductions, corporations and interest free loans. The Tax Equity and Fiscal Responsibility Act (TERFA) is discussed in a separate section.
Use Of Multiple Qualified Pension Plans By Small Employers After The Tax Equity And Fiscal Responsibility Act Of 1982, Daniel R. Sharpe
Use Of Multiple Qualified Pension Plans By Small Employers After The Tax Equity And Fiscal Responsibility Act Of 1982, Daniel R. Sharpe
Akron Tax Journal
Since the adoption of the Employee Retirement Income Security Act of 1974, many employers have adopted more than one pension or profit sharing plan for a variety of reasons. The rules governing the design and structure of multiple pension plans have remained relatively static since 1974 until the adoption of the Tax Equity and Fiscal Responsibility Act of 1982. This article will explore some of the radical changes made by TEFRA to the design and operation of multiple pension plans, particularly by small employers.
Death Of A Partner: Pre And Post-Mortem Planning, Jerome Hesch
Death Of A Partner: Pre And Post-Mortem Planning, Jerome Hesch
Akron Tax Journal
There are several alternative techniques which can be employed to alleviate the income tax problems associated with the death of a partner. The sophisticated tax advisor will understand, however, that some of the suggested techniques may not be practical for all situations. The purpose of this article is to describe these planning techniques and to guide the tax advisor as to which technique is appropriate for his client.
Is The Will The Way? Transmitting Interests In A Family Corporation, Gail Levin Richmond
Is The Will The Way? Transmitting Interests In A Family Corporation, Gail Levin Richmond
Akron Tax Journal
This article examines the effects of recent enactments upon the methods of transmitting interests in a closely-held corporation. Because the tax consequences will frequently vary depending upon whether the corporation is a C corporation or an S corporation, a brief description of each form precedes the discussion of the relevant tax consequences. The tax consequences, which will be discussed thereafter, involve interrelated questions: which consequences are involved, and who will bear their brunt? Because nontax considerations also influence the timing of stock transfers, the discussion will address them as well.
The Step-Transaction Doctrine In Subchapter C: The Search For A Unifying Theory Continues, Robert Willens
The Step-Transaction Doctrine In Subchapter C: The Search For A Unifying Theory Continues, Robert Willens
Akron Tax Journal
This article discusses the Step-Transaction Doctrine in Subchapter C of the Internal Revenue Code. It is generally conceded that the Doctrine can apply if it meets any of the three alternative tests: : the "end result" test, the "mutual interdependence" test, or the more restrictive "binding commitment" test. However, there is difficult in determining which test will apply to the particular transaction under scrutiny. This is explored through a review of decisions dealing with Section 302 which relates to redemptions; Section 351 which deals with corporate organization; Section 368 which governs corporate reorganizations; and finally, the "integrated transaction" doctrine under …
Proceedings From The 1983 Tax Institute Symposium: Corporate Asset And Corporate Stock Acquisitions, Harvey Frutkin
Proceedings From The 1983 Tax Institute Symposium: Corporate Asset And Corporate Stock Acquisitions, Harvey Frutkin
Akron Tax Journal
This article discusses corporate assets and corporate stock acquisitions. It looks at the choices and decisions that are involved in the purchase and sale of a business, including the purchase and sale of a corporation's stock and the corporation's assets. Those are the choices: the asset deal or the stock deal.
Tax Equity And Fiscal Responsibility Act Of 1982, Merlin G. Briner
Tax Equity And Fiscal Responsibility Act Of 1982, Merlin G. Briner
Akron Tax Journal
O N AUGUST 20, 1982, President Reagan signed into law the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), the fourth piece of major tax legislation in less than seven years. Though TEFRA has been said to provide the single largest tax increase in American history, President Reagan lobbied for it not as a tax bill, but as a revenue measure which, to his mind, in no way represented a backing-off from his vaunted "supply side-trickle down" economic program. This article will discuss the implications of TERFA on both the individual taxpayer and businesses.