Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Articles 1 - 3 of 3

Full-Text Articles in Law

Limiting Religious Tax Exemptions: When Should The Church Render Unto Caesar?, Stephen Schwarz Jan 1976

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 Jan 1976

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 Jan 1976

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.