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Full-Text Articles in Law
Selling A Business And Starting Anew: Liquidation-Reincorporation In The Simple Situation, John R. Dorocak
Selling A Business And Starting Anew: Liquidation-Reincorporation In The Simple Situation, John R. Dorocak
Akron Tax Journal
A client approaches his attorney with a fairly common problem. The client, as sole or predominant shareholder, operates a business in the corporate form. He wishes to sell all the assets of that business to a third party. The client will then take the proceeds of the sale, after distribution to himself as shareholder, and use a part of them to capitalize a new corporation, which will purchase a new business. The question for the attorney is whether this simple transaction will ever call forth the tax doctrine of liquidation-reincorporation. This article will examine the likelihood of the liquidation reincorporation …
Proceedings From The 1984 Tax Institute Symposium: Partnerships: Special Allocations Under The New Regulations, The Proposed Regulations Or Whatever, John C. Siegesmund
Proceedings From The 1984 Tax Institute Symposium: Partnerships: Special Allocations Under The New Regulations, The Proposed Regulations Or Whatever, John C. Siegesmund
Akron Tax Journal
This article discusses Section 704 of the Internal Revenue Code and the 1984 proposed regulations related to the section. It looks at the major test of the regulations, that an allocation will be approved if it has substantial economic effect. It examines the two parts of this - that the allocation has to have an economic effect, and that the economic effect has to be substantial.
Proceedings From The 1984 Tax Institute Symposium: Cash Or Deferred Arrangements Under I.R.C. Section 401(K), John H. Appel
Proceedings From The 1984 Tax Institute Symposium: Cash Or Deferred Arrangements Under I.R.C. Section 401(K), John H. Appel
Akron Tax Journal
This article examines the reasons why an employer might consider a cash or deferred profit sharing or stock bonus plan. It looks at the rules for a cash or deferred arrangement (CODA) under Section 401(k) of the Internal Revenue Code. It covers the four primary requirements under the I.R.C., and then fifth, and biggest requirement, nondiscrimination.
Federal Income Tax Developments: 1983, Merlin G. Briner, Richard J. Kovach
Federal Income Tax Developments: 1983, Merlin G. Briner, Richard J. Kovach
Akron Tax Journal
This article surveys substantive federal income tax developments in 1983, including relevant Supreme Court cases, deductions, legislative and treasury regulations, and income recognition and related topics.
Report On Tax Aspects Of Farmers In Bankruptcy, Ralph T. Turner
Report On Tax Aspects Of Farmers In Bankruptcy, Ralph T. Turner
Akron Tax Journal
This article will deal only with the individual taxpayer who utilizes the bankruptcy court and not with the tax treatment of corporations and partnerships in bankruptcy. There are special rules for the tax treatment of these entities. This article will review the general principles of tax treatment of an individual whose indebtedness was discharged in bankruptcy under the prior law and under the Bankruptcy Tax Act of 1980. After this general review and comments on their application to farmers, a hypothetical fact situation will be reviewed and the handling of the tax returns for the individual and the bankruptcy estate …
Over The Back Fence: Tax Shelters And Other Sales Of Federal Income Tax Reductions, Thomas A. Robinson
Over The Back Fence: Tax Shelters And Other Sales Of Federal Income Tax Reductions, Thomas A. Robinson
Akron Tax Journal
Structural features of the federal income tax system frequently make the same tax reduction' more valuable to one taxpayer than to another. There are many types of such tax reductions (including deductions and credits), creating a fertile environment for the tax shelter markets. Black letter law says tax reductions are nontransferable. In other words, taxpayers are not allowed to sell their mortgage interest deductions over the back fence to their neighbors. Yet, observation reveals some transactions where tax reductions are in effect bought and sold. This article will examine four of these transactions: business sales, divorce agreements, sale-leasebacks, and partnership …