Law Commons^™

Federal Income Taxation-Accounting Methods-Accounting For Prepayments And Estimated Future Expenses, Jerome M. Salle S.Ed.

Michigan Law Review

"It is the essence of any system of taxation that it should produce revenue ascertainable, and payable to the government, at regular intervals." In order to obtain regular periodic revenues from the federal income tax, Congress requires all taxpayers to determine their taxable income annually.

Income may be defined as "value added" as a result of a given economic activity. Logically, the most opportune time to measure income occurs whenever that activity has ended, for at that time the continuous growth or contraction in the attributable value will likewise have ended and the income or loss from the activity will …

Taxation-Federal Income Tax-Liquidation Distributions Entitled To Both Capital Gains Treatment And Foreign Tax Credit, Lloyd C. Fell

Michigan Law Review

Plaintiff, Associated, is an American corporation whose wholly-owned subsidiary, Automatic, owned all the stock of Filcrest, a Canadian corporation. In 1954 all the assets of Filcrest were distributed to Automatic pursuant to a plan of complete liquidation, accomplished in accordance with Canadian law. In its 1954 consolidated return, plaintiff treated the gain realized on the Filcrest liquidation as a capital gain, and also claimed a foreign tax credit for any Canadian income, war or excess profits taxes which Filcrest had paid over the years to Canada on that part of the liquidation distribution which represented Filcrest's accumulated earnings and profits. …