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Full-Text Articles in Law
Unwinding The Ceiling Rule, Leigh Osofsky
Unwinding The Ceiling Rule, Leigh Osofsky
Articles
This article closely examines the unwinding of the ceiling rule. Congress and partnership tax experts historically have assumed perfect unwinding of the ceiling rule on liquidation or sale of a partnership interest. However, this assumption glosses over a significantly more complicated reality. This article closely examines the history of section 704(c) and the interaction between the ceiling rule and the rules regarding sales and liquidations of partnership interests to reveal the extent to which the assumption does not hold. By debunking long-held assumptions about the perfect unwinding of the ceiling rule, this article displays that there is no reasonable justification …
What Makes A Dutch Company Dutch? The Evolution Of Us Limitation-On-Benefits Provisions, Patricia A. Brown
What Makes A Dutch Company Dutch? The Evolution Of Us Limitation-On-Benefits Provisions, Patricia A. Brown
Articles
No abstract provided.
Citizens United And Social Welfare Organizations: The Tangled Relationships Among Guidance, Compliance, And Enforcement, Frances R. Hill
Citizens United And Social Welfare Organizations: The Tangled Relationships Among Guidance, Compliance, And Enforcement, Frances R. Hill
Articles
No abstract provided.