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Articles 1 - 22 of 22
Full-Text Articles in Law
Initial Pitfalls Associated With Use Of The Limited Partnership, Michael T. Madison
Initial Pitfalls Associated With Use Of The Limited Partnership, Michael T. Madison
William & Mary Annual Tax Conference
No abstract provided.
The Corporate General Partner In A Limited Partnership, Henry Weiler
The Corporate General Partner In A Limited Partnership, Henry Weiler
William & Mary Annual Tax Conference
No abstract provided.
Constructive Cash Distributions, John W. Lee
Constructive Cash Distributions, John W. Lee
William & Mary Annual Tax Conference
No abstract provided.
Collapsible Partnerships, Michael S. Applebaum
Collapsible Partnerships, Michael S. Applebaum
William & Mary Annual Tax Conference
No abstract provided.
Compensating The Promoter-General Partner, Martin B. Cowan
Compensating The Promoter-General Partner, Martin B. Cowan
William & Mary Annual Tax Conference
No abstract provided.
Tax Shelter Reform, Richard M. Leder
Tax Shelter Reform, Richard M. Leder
William & Mary Annual Tax Conference
No abstract provided.
Moe V. Confederated Salish & Kootenai Tribes Of The Flatland Reservation, Lewis F. Powell Jr.
Moe V. Confederated Salish & Kootenai Tribes Of The Flatland Reservation, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
Divorce, Tax-Style, Alan L. Feld
Divorce, Tax-Style, Alan L. Feld
Faculty Scholarship
In response to the "sham divorce" tactic, the IRS recently issued Revenue Ruling 76-255. The author, professor of law at Boston University School of Law, although sympathetic with the IRS's position in the Ruling, poin4s out situations where the divorce-remarriage may possibly be considered valid because of the existence of nontax effects.
Credited Service After Erisa, John W. Lee
The "Elaborate Interweaving Of Jurisdiction": Labor And Tax Administration And Enforcement Of Erisa And Beyond, John W. Lee
The "Elaborate Interweaving Of Jurisdiction": Labor And Tax Administration And Enforcement Of Erisa And Beyond, John W. Lee
Faculty Publications
No abstract provided.
State Taxation Of Interstate Business And The Supreme Court, 1974 Term: Standard Pressed Steel And Colonial Pipeline, Walter Hellerstein
State Taxation Of Interstate Business And The Supreme Court, 1974 Term: Standard Pressed Steel And Colonial Pipeline, Walter Hellerstein
Scholarly Works
It was an item of more than routine interest when the Supreme Court, late in the 1973 term, noted probable jurisdiction in two cases raising issues of central importance with respect to state tax power over interstate business. Standard Pressed Steel Co. v. Department of Revenue presented critical questions concerning due process and commerce clause limitations on a state's power to impose an unapportioned gross receipts tax on an interstate vendor; Colonial Pipeline Co. v. Traigle posed the recurring and unresolved question of the scope and vitality of the doctrine that the “privilege” of doing interstate business is immune from …
Partnership Allocations, Donald J. Weidner
Partnership Allocations, Donald J. Weidner
William & Mary Annual Tax Conference
No abstract provided.
Report On The Internal Training Program Of Zambia’S Department Of Taxes, Richard Pomp
Report On The Internal Training Program Of Zambia’S Department Of Taxes, Richard Pomp
Faculty Articles and Papers
This report covers a review of the internal training program of Zambia’s Department of Taxes in 1975 and offers numerous suggestions for improvement. The report begins with a brief description of the courses of study in the training program, followed by a discussion of problem areas of the three main components of each course (field training, classroom instruction, and examinations) with recommendations for reform. After noting a general dissatisfaction with the quality of trainees the Tax Department attracts, the report suggests two main avenues for improvement. One avenue is establishing working conditions that attract and keep high-quality individuals. The other …
The Case For Highly Graduated Rates In State Income Taxes, Robert I. Keller
The Case For Highly Graduated Rates In State Income Taxes, Robert I. Keller
Faculty Scholarship
No abstract provided.
Tax Policy Implications Of Contributions Of Appreciated And Depreciated Property To Partnerships, Subchapter C Corporations And Subchapter S Corporations In Exchange For Ownership Interests, Samuel C. Thompson Jr.
Tax Policy Implications Of Contributions Of Appreciated And Depreciated Property To Partnerships, Subchapter C Corporations And Subchapter S Corporations In Exchange For Ownership Interests, Samuel C. Thompson Jr.
Journal Articles
No abstract provided.
The Ab (Abc) And Ba Transactions: An Economic And Tax Analysis Of Reserved And Carved Out Income Interests, Kenneth F. Joyce, Louis A. Del Cotto
The Ab (Abc) And Ba Transactions: An Economic And Tax Analysis Of Reserved And Carved Out Income Interests, Kenneth F. Joyce, Louis A. Del Cotto
Journal Articles
No abstract provided.
Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee
Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee
Faculty Publications
The IRS in three Rulings has taken the position that services for the distributing corporation performed through independent contractor could not satisfy the active business requirement test of Section 355. Mr. Lee analyzes the Rulings in light of case law and legislative history that have interpreted the Code's active business test. He concludes that further court tests will be necessary before there can be complete reliance upon active conduct by an independent contractor.
How To Salvage Tax Benefits When A Professional Corporation Disbands, John W. Lee
How To Salvage Tax Benefits When A Professional Corporation Disbands, John W. Lee
Faculty Publications
One of the main concerns of a shareholder in a professional corporation that is dissolving is to protect his interest in the corporation's qualified deferred compensation plan. By use of a case study, Mr. Lee analyzes several methods available for a shareholder to preserve his interest. He also presents a possible solution to other problems arising in connection with the professional corporation's dissolution, such as splitting up the practice (and its accounts receivable) and the status of liquidating distributions if the professionals reincorporate separately.
Michelin Tire Corp. V. Wages: Enhanced State Power To Tax Imports, Walter Hellerstein
Michelin Tire Corp. V. Wages: Enhanced State Power To Tax Imports, Walter Hellerstein
Scholarly Works
In Michelin Tire Corp. v. Wages, the Supreme Court abandoned a century of precedent in holding that the Import-Export Clause does not bar a state from imposing a nondiscriminatory ad valorem property tax on imported goods. The provision forbidding the states from laying "any Imposts or Duties on Imports or Exports" was never intended to prohibit such a levy, the Court now tells us, and the case first suggesting that it did, Low v. Austin, was "wrong decided." Over a mild protest of Mr. Justice White, the Court thus obviated any examination of the principal issue the parties …
Technical And Scientific Evidence In Administrative Adjudication, Scott C. Whitney
Technical And Scientific Evidence In Administrative Adjudication, Scott C. Whitney
Faculty Publications
No abstract provided.
Recent Tax Court Case Suggests Expanded Use Of Multiple Corporations, Edwin T. Hood
Recent Tax Court Case Suggests Expanded Use Of Multiple Corporations, Edwin T. Hood
Faculty Works
No abstract provided.
Reconciling Business Purpose With Bail-Out Prevention: Federal Tax Policy And Corporate Divisions, Stephen B. Cohen
Reconciling Business Purpose With Bail-Out Prevention: Federal Tax Policy And Corporate Divisions, Stephen B. Cohen
Georgetown Law Faculty Publications and Other Works
Corporate divisions-spin-offs, split-offs, and split-ups-unfortunately pose a more complex problem than Senator Humphrey's childlike vision would lead one to believe: the reconciliation of competing goals of maximizing business flexibility and minimizing tax avoidance. It is widely believed that divisions are essential to business planning; thus, tax-free treatment promotes business flexibility. Yet, an untaxed division may allow tax avoidance through "bail-out" of corporate earnings and profits at capital gain rates.