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Full-Text Articles in Law
The Physical Consequences Of Emotional Distress: The Need For A New Test To Determine What Amounts Are Excluded From Gross Income Under § 104(A)(2), C. Anthony Wolfe Iv
The Physical Consequences Of Emotional Distress: The Need For A New Test To Determine What Amounts Are Excluded From Gross Income Under § 104(A)(2), C. Anthony Wolfe Iv
Washington and Lee Law Review
No abstract provided.
Fatca: Toward A Multilateral Automatic Information Reporting Regime, Joanna Heiberg
Fatca: Toward A Multilateral Automatic Information Reporting Regime, Joanna Heiberg
Washington and Lee Law Review
No abstract provided.
Examining The Tax Advantage Of Founders' Stock, Gregg D. Polsky, Brant J. Hellwig
Examining The Tax Advantage Of Founders' Stock, Gregg D. Polsky, Brant J. Hellwig
Scholarly Articles
Recent commentary has described founders' stock as tax-advantaged because it converts founders' compensation income into capital gains. In this paper we describe various founders' stock strategies that offer this character conversion and then analyze whether they are, on the whole, tax advantageous. While the founders' stock strategies favorably convert the character of the founders' income, they simultaneously turn the company's compensation deductions into non-deductions. Whether founders' stock is tax-advantaged overall depends on whether the benefit of the founders' character conversion outweighs the cost of the company's lost deductions. We use various hypothetical to illustrate this tradeoff. We conclude that founders' …