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Full-Text Articles in Law
Section 338(H)(10), Mark L. Yecies
Section 338(H)(10), Mark L. Yecies
William & Mary Annual Tax Conference
No abstract provided.
Proposed Intercompany Transaction Regulations: Side-By-Side Comparisons, Andrew J. Dubroff
Proposed Intercompany Transaction Regulations: Side-By-Side Comparisons, Andrew J. Dubroff
William & Mary Annual Tax Conference
No abstract provided.
Final Consolidated Return Regulations Modifying The Calculation Of Stock Basis And Other Items, Kevin A. Duvall
Final Consolidated Return Regulations Modifying The Calculation Of Stock Basis And Other Items, Kevin A. Duvall
William & Mary Annual Tax Conference
No abstract provided.
Selected Issues In Operating An S Corporation, Thomas P. Rohman
Selected Issues In Operating An S Corporation, Thomas P. Rohman
William & Mary Annual Tax Conference
No abstract provided.
Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon
Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon
William & Mary Annual Tax Conference
No abstract provided.
Planning For The Termination Of An Interest In A Partnership - Withdrawals, Distributions And Other Exit Strategies, Michael G. Frankel
Planning For The Termination Of An Interest In A Partnership - Withdrawals, Distributions And Other Exit Strategies, Michael G. Frankel
William & Mary Annual Tax Conference
No abstract provided.
Federal Income Tax Considerations Of Acquisitions Involving S Corporations, Mary L. Harmon
Federal Income Tax Considerations Of Acquisitions Involving S Corporations, Mary L. Harmon
William & Mary Annual Tax Conference
No abstract provided.
C To S To C Conversions, Bryan P. Collins
C To S To C Conversions, Bryan P. Collins
William & Mary Annual Tax Conference
No abstract provided.
Federal Taxation On Disposition Of Partnership Interests, Richard A. Shaw
Federal Taxation On Disposition Of Partnership Interests, Richard A. Shaw
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entity: S Corporations And Limited Liability Companies, Samuel P. Starr
Choice Of Entity: S Corporations And Limited Liability Companies, Samuel P. Starr
William & Mary Annual Tax Conference
No abstract provided.
Planning With S Corporations, Richard A. Shaw
Planning With S Corporations, Richard A. Shaw
William & Mary Annual Tax Conference
No abstract provided.
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 1), John W. Lee
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 1), John W. Lee
Faculty Publications
In this article, Lee charts two alternative methods for implementing an aggregate solution to the problem of partnership profits share exchanged for services. The functional, or judicial, method, he explains, is to handle (1) the exchange of partner-capacity services for a profit share subject to the risk of the venture with the Culbertson "common law relation of partnership," nonrealization event doctrine, implicitly contemplated by the 1984 legislative history to section 707(a)(2); (2) the classic Diamond transitory partner with a substance-over-form rule or step-transaction rule; and (3) a sale of the partnership interest in circumstances that would result in ordinary income …