Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Taxation (3)
- Tax (2)
- Tax law (2)
- 401k (1)
- 734 (1)
-
- 743 (1)
- Annuity contracts (1)
- Basis adjustments (1)
- Buildup tax treatment (1)
- Corporate Taxation (1)
- Corporate tax (1)
- Federal Tax Procedure (1)
- Hedge fund wrappers (1)
- Imputation (1)
- Income Taxation (1)
- Individual Retirement Account (IRA) (1)
- Inside basis (1)
- Integration (1)
- Internal Revenue Service (1)
- International tax (1)
- International trade (1)
- Investment Company Act of 1940 (1)
- Investor control doctrine (1)
- Loss duplication (1)
- Money market funds (1)
- Mutual fund reform (1)
- Partial liquidation (1)
- Partnership (1)
- Partnership Taxation (1)
- Tax agreements (1)
Articles 1 - 6 of 6
Full-Text Articles in Law
Repairing Inside Basis Adjustments, Karen C. Burke
Repairing Inside Basis Adjustments, Karen C. Burke
UF Law Faculty Publications
Optional basis adjustments under Subchapter K have come under increased scrutiny as a result of tax shelter abuses involving partnerships. Recent legislation requires mandatory adjustments under sections 734(b) and 743(b) upon certain distributions of partnership property and transfers of partnership interests. These amendments were targeted at situations in which the failure to make such adjustments potentially gave rise to duplication of losses. While preventing loss duplication may be particularly urgent, these anti-tax-shelter measures represent a retreat from broader proposals calling for mandatory section 734(b) adjustments for both current and liquidating distributions.
In a recent article, Professor Abrams criticizes the common …
Integration In An Integrating World, Yariv Brauner
Integration In An Integrating World, Yariv Brauner
UF Law Faculty Publications
During the second half of the last century, many countries gradually replaced their so-called classical corporate tax regimes, under which corporate earnings were taxed twice -- once in the hands of the corporation, and again when distributed to corporate shareholders as dividends -- with an integrated regime (imputation), which taxed such earnings only once. The driving force behind this trend was the expectation of significant efficiency gains. This clear and gradual trend has been abruptly reversed with the turn of the century. The phenomenon we call globalization, and in particular the proliferation of cross-border business and investment, has materially contributed …
International Trade And Tax Agreements May Be Coordinated, But Not Reconciled, Yariv Brauner
International Trade And Tax Agreements May Be Coordinated, But Not Reconciled, Yariv Brauner
UF Law Faculty Publications
A recent WTO case held the U.S.' export tax subsidies illegal. Despite strong political resistance, which fed a long and costly legislative process, the U.S. recently repealed these subsidies. This case and the U.S. reaction revealed that although the U.S. is the single super economic power, it is not as dominant a player as some portray it. The case also shed light on the tension between the present international trade and tax regimes and the difficulty of applying WTO law to income tax measures. This tension did not escalate earlier mainly because countries tended not to use their income tax …
Recent Developments In Federal Income Taxation: The Year 2004, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation: The Year 2004, Ira B. Shepard, Martin J. Mcmahon Jr.
UF Law Faculty Publications
This recent developments outline discusses, and provides context to understand the significance of, the most important judicial decisions and administrative rulings and regulations promulgated by the Internal Revenue Service and Treasury Department during 2004 - and sometimes a little farther back in time if we find the item particularly humorous or outrageous. Most Treasury Regulations, however, are so complex that they cannot be discussed in detail and, anyway, only a devout masochist would read them all the way through; just the basic topic and fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …
Beating The 'Wrap': The Agency Effort To Control Wraparound Insurance Tax Shelters, Charlene Luke
Beating The 'Wrap': The Agency Effort To Control Wraparound Insurance Tax Shelters, Charlene Luke
UF Law Faculty Publications
The first wraparound insurance tax shelter was marketed in the mid-1960s as a means for contract owners to exploit the inconsistency arising from the difference in the tax treatment of investment returns earned inside variable insurance contracts and the economically similar returns available outside such contracts. Federal income tax is deferred (and in some cases eliminated) on the income accruing inside variable insurance products - called inside buildup. In the most recent iteration of the wraparound insurance gambit, insurance companies wrapped private-placement, hedge-fund interests inside variable insurance products in order to allow contract owners to defer tax on the ordinary …
The Unfinished Business Of Mutual Fund Reform, Thomas R. Hurst
The Unfinished Business Of Mutual Fund Reform, Thomas R. Hurst
UF Law Faculty Publications
The need for further mutual fund reform remains in two major areas. First, there is a need for greater and more effective disclosure of fund charges and greater transparency in the manner in which funds operate. While it is probably overly optimistic to expect that this will make a dramatic difference in investors' preferences for one fund over another, at least it will make it possible for the investor who does care about costs and conflicts of interest to determine how efficiently a particular fund is managed vis-a-vis its competitors. A generation ago, funds with a front end sales load …