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

2011

Selected Works

Tax Law

Business and Individual Taxation

Articles 1 - 10 of 10

Full-Text Articles in Law

Interest Elements In Tax Planning, Daniel S. Goldberg Apr 2011

Interest Elements In Tax Planning, Daniel S. Goldberg

Daniel S. Goldberg

This article discusses how interest has been and is being used in tax planning. The tax planning techniques using interest include charging too little interest or none at all, recalssifying interest as principal and allocating interest among time periods to optimize the tax consequences to the parties. The issues raised by these tax planning techniques go to the heart of the tax system. They suggest inadequacies in the development of the case law and in conventional tax thinking. The unifying principal is the divergence between the possible tax consequences and the clear economic consequences of each of the transactions. The …

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Nonrecourse Debt In Excess Of Fair Market Value: The Confluence Of Basis, Realization, Subchapter K And The Need For Consistency, Daniel S. Goldberg Apr 2011

Nonrecourse Debt In Excess Of Fair Market Value: The Confluence Of Basis, Realization, Subchapter K And The Need For Consistency, Daniel S. Goldberg

Daniel S. Goldberg

No abstract provided.

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Open Transaction Treatment For Deferred Payment Sales After The Installment Sales Act Of 1980, Daniel S. Goldberg Apr 2011

Open Transaction Treatment For Deferred Payment Sales After The Installment Sales Act Of 1980, Daniel S. Goldberg

Daniel S. Goldberg

No abstract provided.

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The Tax Treatment Of Limited Liability Companies: Law In Search Of Policy, Daniel S. Goldberg Apr 2011

The Tax Treatment Of Limited Liability Companies: Law In Search Of Policy, Daniel S. Goldberg

Daniel S. Goldberg

No abstract provided.

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Fair Market Value In The Tax Law: Replacement Value Or Liquidation Value, Daniel Goldberg Apr 2011

Fair Market Value In The Tax Law: Replacement Value Or Liquidation Value, Daniel Goldberg

Daniel S. Goldberg

No abstract provided.

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The Passive Activity Loss Rules: Planning Considerations, Techniques, And A Foray Into Never-Never Land, Daniel S. Goldberg Apr 2011

The Passive Activity Loss Rules: Planning Considerations, Techniques, And A Foray Into Never-Never Land, Daniel S. Goldberg

Daniel S. Goldberg

No abstract provided.

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Choice Of Entity For A Venture Capital Start-Up: The Myth Of Incorporation, Daniel S. Goldberg Apr 2011

Choice Of Entity For A Venture Capital Start-Up: The Myth Of Incorporation, Daniel S. Goldberg

Daniel S. Goldberg

No abstract provided.

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Lifetime Gifts - A Quantitative Approach, Roger A. Pies, Daniel S. Goldberg Apr 2011

Lifetime Gifts - A Quantitative Approach, Roger A. Pies, Daniel S. Goldberg

Daniel S. Goldberg

No abstract provided.

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Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel Goldberg Apr 2011

Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel Goldberg

Daniel S. Goldberg

No abstract provided.

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Recent Approaches To The Trade Or Business Requirement Of Section 174: Unauthorized Snow Removal, Daniel S. Goldberg Apr 2011

Recent Approaches To The Trade Or Business Requirement Of Section 174: Unauthorized Snow Removal, Daniel S. Goldberg

Daniel S. Goldberg

No abstract provided.

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