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Articles 1 - 5 of 5
Full-Text Articles in Law
Linton Family Llc And The Step Transaction Doctrine, Wendy G. Gerzog
Linton Family Llc And The Step Transaction Doctrine, Wendy G. Gerzog
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This article discusses Linton, a district court decision about a family limited liability company, indirect gifts, and the step transaction doctrine.
Families For Tax Purposes: What About The Steps, Wendy G. Gerzog
Families For Tax Purposes: What About The Steps, Wendy G. Gerzog
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At least 4.4 million families in the U.S. are blended ones that include step-children and step-parents. For tax purposes, these steps receive preferential treatment for their status because they are on the one hand included as family members for many income tax benefit sections, but on the other hand excluded as family members for business entity attribution purposes and for gift and estate tax anti-abuse provisions. In the interests of fairness and uniformity, steps should be treated as family members for all tax purposes where steps have in fact voluntarily acted as their biological or adoptive counterparts, both when such …
Negron: Circuits Now Split 2-2, Wendy G. Gerzog
Negron: Circuits Now Split 2-2, Wendy G. Gerzog
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The article discusses Negron and the circuit split on the issue of whether to value non-assignable lottery payments in a decedent's estate by means of the actuarial tables or whether that value needs to be discounted for non-marketability.
Integrating Subchapters K And S — Just Do It, Walter D. Schwidetzky
Integrating Subchapters K And S — Just Do It, Walter D. Schwidetzky
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The Code contains two “pass-through” tax regimes for business entities. One is contained in Subchapter K, which applies to partnerships, the other in Subchapter S, which, unsurprisingly, applies to S corporations. In the main, both Subchapters tax the owners of the entities rather than the entities themselves. Having two pass-through tax regimes creates obvious administrative and other inefficiencies. There was a time when S corporations served a valuable purpose, particularly when taxpayers needed a fairly simple and foolproof pass-through entity that provided a liability shield. But limited liability companies (LLCs), which are usually taxed as partnerships, 1 in most contexts …
Return Of The Poll Tax: How The Internet Threatens 200 Years Of Progress Toward Equality, Max Oppenheimer
Return Of The Poll Tax: How The Internet Threatens 200 Years Of Progress Toward Equality, Max Oppenheimer
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No abstract provided.