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Full-Text Articles in Law
Limiting Religious Tax Exemptions: When Should The Church Render Unto Caesar?, Stephen Schwarz
Limiting Religious Tax Exemptions: When Should The Church Render Unto Caesar?, Stephen Schwarz
Faculty Scholarship
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.
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.