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Full-Text Articles in Law
Estate Freezes, Ronald D. Aucutt
Estate Freezes, Ronald D. Aucutt
William & Mary Annual Tax Conference
No abstract provided.
Aftermath Of The 1986 Tax Reform Act- Part Ii, Louis H. Diamond
Aftermath Of The 1986 Tax Reform Act- Part Ii, Louis H. Diamond
William & Mary Annual Tax Conference
No abstract provided.
Civil Penalties Under The Internal Revenue Code, L. Paige Marvel
Civil Penalties Under The Internal Revenue Code, L. Paige Marvel
William & Mary Annual Tax Conference
No abstract provided.
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, Richard E. Levine, David H. Evaul
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, Richard E. Levine, David H. Evaul
William & Mary Annual Tax Conference
No abstract provided.
Termination Of Partnerships And Of Partnership Interests, Louis A. Mezzullo
Termination Of Partnerships And Of Partnership Interests, Louis A. Mezzullo
William & Mary Annual Tax Conference
No abstract provided.
Termination Of S Corporations And Of S Shareholder Interests, Morton A. Harris, Russell E. Hinds
Termination Of S Corporations And Of S Shareholder Interests, Morton A. Harris, Russell E. Hinds
William & Mary Annual Tax Conference
No abstract provided.
Operation Of And Distributions From S Corporations, Deborah H. Schenk
Operation Of And Distributions From S Corporations, Deborah H. Schenk
William & Mary Annual Tax Conference
No abstract provided.
Partnership Operations And Distributions, Steven M. Friedman
Partnership Operations And Distributions, Steven M. Friedman
William & Mary Annual Tax Conference
No abstract provided.
Structuring Real Estate Investments And Transactions After Tra 1986, Charles H. Egerton
Structuring Real Estate Investments And Transactions After Tra 1986, Charles H. Egerton
William & Mary Annual Tax Conference
No abstract provided.
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Articles
The General Utilities doctrine is the name given to the now largely defunct tax rule that a corporation does not recognize a gain or a loss on making a liquidating or nonliquidating distribution of an appreciated or depreciated asset to its shareholders. The roots of the doctrine, can be traced to a regulation promulgated in 1919 that denied realization of gain or loss to a corporation when making a liquidating distribution of an asset in kind. No regulatory provision existed which specified the extent to which realization would or would not be triggered by a nonliquidating distribution such as a …