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Articles 1 - 13 of 13
Full-Text Articles in Law
Fact Sheet: Water Licences, New South Wales Aboriginal Land Council
Fact Sheet: Water Licences, New South Wales Aboriginal Land Council
Indigenous Water Justice Symposium (June 6)
Presenter: Phil Duncan, Gomeroi Nation, New South Wales Aboriginal Land Council
4 pages
Contains references
The Problem Of Abusive Related-Partner Allocations, Gregg D. Polsky, Emily Cauble
The Problem Of Abusive Related-Partner Allocations, Gregg D. Polsky, Emily Cauble
Scholarly Works
This Article highlights a flaw in the existing rules regarding partnership tax allocations that has not yet received sufficient attention by existing literature. Namely, the partnership tax allocation rules are implicitly premised on the assumption that partners are unrelated and, thus, transact with each other at arm’s length. As a result, related partners can and do devise tax allocation schemes that exploit the gap in the current partnership tax allocation rules to achieve unwarranted tax savings.
This Article proposes to end this abuse by disallowing special allocations among related partners. Under the proposal, allocations among related partners would be required …
S11rs Sgr No. 4 (Finance Reformation), Wells, Abshire, Alexander, Ardoin, Baudoin, Beadle, Bourg, Breaud, David, Derenbecker, Duckett, Ehrhardt, Geoffrey, Gillum, Gist, Guillory, Guinn, Harding, Hebert, Hess, Hill, Jefcoat, Jones, Kelly, Kennedy, Lemoine, Lockwood, Loga, Marks, Naquin, Nipper, Pace, Polander, Robison, Scott, Sellers, Simon, Soileau, Sullivan, Taylor, Terracciano, Trout, Vaughn, Voss, Westbrook, Zeringue, Caffarel, Bonvillain
S11rs Sgr No. 4 (Finance Reformation), Wells, Abshire, Alexander, Ardoin, Baudoin, Beadle, Bourg, Breaud, David, Derenbecker, Duckett, Ehrhardt, Geoffrey, Gillum, Gist, Guillory, Guinn, Harding, Hebert, Hess, Hill, Jefcoat, Jones, Kelly, Kennedy, Lemoine, Lockwood, Loga, Marks, Naquin, Nipper, Pace, Polander, Robison, Scott, Sellers, Simon, Soileau, Sullivan, Taylor, Terracciano, Trout, Vaughn, Voss, Westbrook, Zeringue, Caffarel, Bonvillain
Student Senate Enrolled Legislation
No abstract provided.
New Mexico Water Stake In The Colorado River, Estevan R. Lopez
New Mexico Water Stake In The Colorado River, Estevan R. Lopez
Hard Times on the Colorado River: Drought, Growth and the Future of the Compact (Summer Conference, June 8-10)
Presenter: Estevan R. Lopez, Interstate Stream Commission, New Mexico.
2 pages.
History Of Colorado River Law, Development And Use: A Primer And Look Forward, Greg Hobbs, Jr.
History Of Colorado River Law, Development And Use: A Primer And Look Forward, Greg Hobbs, Jr.
Hard Times on the Colorado River: Drought, Growth and the Future of the Compact (Summer Conference, June 8-10)
Presenter: Greg Hobbs, Jr., Colorado Supreme Court.
25 pages.
Contains references.
Legal Durability, Omri Ben-Shahar
Legal Durability, Omri Ben-Shahar
Articles
This paper develops a framework to study the effects of the durability of legal allocation decisions, such as trial outcomes, regulatory enactments and property entitlements. For a party favored by the legal allocation, a more durable decision is also more costly to secure, ex-ante. Thus, it is not the greater durability of the allocation that determines whether the “winner” is better-off, but other factors that are affected by the durability attribute, such as the cost of securing a favorable outcome and the ability of contesting parties to affect this cost. The paper develops conditions under which greater durability is irrelevant, …
Exculpatory Liabilities And Partnership Nonrecourse Allocations, Karen C. Burke
Exculpatory Liabilities And Partnership Nonrecourse Allocations, Karen C. Burke
UF Law Faculty Publications
The rise of limited liability companies (LLCs) classified as partnerships for federal income tax purposes challenges traditional assumptions concerning the treatment of recourse and nonrecourse liabilities under Subchapter K. The complex rules of sections 704(b) and 752 give little attention to liabilities that are recourse to the entity under section 1001 but for which no member bears the economic risk of loss under section 752. In comparison to traditional general or limited partnerships, however, LLCs are much more likely to incur such "exculpatory" liabilities because of the limited liability shield under state law. Although exculpatory liabilities are functionally quite similar …
Municipal Demands As The Stimulus For Innovation: Tales From The Lower Colorado River Basin, Jerome C. Muys
Municipal Demands As The Stimulus For Innovation: Tales From The Lower Colorado River Basin, Jerome C. Muys
Water and Growth in the West (Summer Conference, June 7-9)
17 pages.
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
William & Mary Annual Tax Conference
No abstract provided.
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
William & Mary Annual Tax Conference
No abstract provided.
Policies To Enhance Western Water Use Efficiency: Best Of The West, Bruce C. Driver
Policies To Enhance Western Water Use Efficiency: Best Of The West, Bruce C. Driver
Western Water: Expanding Uses/Finite Supplies (Summer Conference, June 2-4)
18 pages.
The Central Arizona Project, Jon Kyl
The Central Arizona Project, Jon Kyl
New Sources of Water for Energy Development and Growth: Interbasin Transfers: A Short Course (Summer Conference, June 7-10)
38 pages (includes illustrations).
Contains footnotes.
Contains 9 attachments.