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Articles 1081 - 1110 of 1180
Full-Text Articles in Business Organizations Law
Observance Of Indicia Of Corporate Characteristics Liquidation Problems, M. Carr Ferguson Jr.
Observance Of Indicia Of Corporate Characteristics Liquidation Problems, M. Carr Ferguson Jr.
William & Mary Annual Tax Conference
No abstract provided.
Taxation--Loss Carry-Back Privileges Of F Reorganizations, Michael J. Moyle
Taxation--Loss Carry-Back Privileges Of F Reorganizations, Michael J. Moyle
West Virginia Law Review
No abstract provided.
Section 355'S Active Business Rule--An Outdated Inefficacy, John A. Stemmler
Section 355'S Active Business Rule--An Outdated Inefficacy, John A. Stemmler
Vanderbilt Law Review
In order to delineate the problems inherent in the active business rule, this Note first will examine the legislative history of tax-free separations, isolating the primary purpose and policy of section 355. Regulatory and judicial interpretations of section 355 will also be analyzed to determine their propriety in light of the statute's purpose and to illustrate the confusion that exists in the area. This, in turn, will lead to a suggested approach for dealing with section 355 transactions in the future.
Taxation--Reserve For Bad Debt, Dennis C. Sauter
Taxation--Reserve For Bad Debt, Dennis C. Sauter
West Virginia Law Review
No abstract provided.
Section 482 And The Integrated Business Enterprise, John W. Lee
Section 482 And The Integrated Business Enterprise, John W. Lee
Faculty Publications
No abstract provided.
Defining Dividend Equivalency Under Section 302(B)(1), Alan R. Gordon
Defining Dividend Equivalency Under Section 302(B)(1), Alan R. Gordon
Villanova Law Review (1956 - )
No abstract provided.
Taxation Of Nonstatutory Stock Options - A Proposed Answer To A Continuing Problem, Thomas C. Riley
Taxation Of Nonstatutory Stock Options - A Proposed Answer To A Continuing Problem, Thomas C. Riley
Villanova Law Review (1956 - )
No abstract provided.
The Liquidation-Reincorporation Device - Analysis And Proposed Solutions, Bruce D. Lombardo, Thomas C. Riley
The Liquidation-Reincorporation Device - Analysis And Proposed Solutions, Bruce D. Lombardo, Thomas C. Riley
Villanova Law Review (1956 - )
No abstract provided.
Recent Decisions
University of Richmond Law Review
This is a summary of the case law from 1968.
The Tax Benefit, Recoveries, And Sales Of Property Under Section 337, Don L. Ricketts
The Tax Benefit, Recoveries, And Sales Of Property Under Section 337, Don L. Ricketts
William & Mary Law Review
No abstract provided.
Interest-Free Loans And Section 482 - Creation Of Income?, Paul E. Holtzmuller
Interest-Free Loans And Section 482 - Creation Of Income?, Paul E. Holtzmuller
William & Mary Law Review
No abstract provided.
Blocked Income Of Controlled Foreign Corporations, Herbert I. Lazerow
Blocked Income Of Controlled Foreign Corporations, Herbert I. Lazerow
Indiana Law Journal
No abstract provided.
Western Hemisphere Trade Corporations: Reconsidered, David L. Gibson
Western Hemisphere Trade Corporations: Reconsidered, David L. Gibson
William & Mary Law Review
No abstract provided.
Income Tax--Reincorporation And Liquidation, Jacob Michael Robinson
Income Tax--Reincorporation And Liquidation, Jacob Michael Robinson
West Virginia Law Review
No abstract provided.
Depreciation And The Reserve Ratio Test, J. Timothy Phillips
Depreciation And The Reserve Ratio Test, J. Timothy Phillips
West Virginia Law Review
No abstract provided.
New Importance For Section 482 Of The Internal Revenue Code, Robert N. Lent
New Importance For Section 482 Of The Internal Revenue Code, Robert N. Lent
William & Mary Law Review
No abstract provided.
Income Tax--Corporate Reorganizations-Spin-Offs, Raymond Albert Hinerman
Income Tax--Corporate Reorganizations-Spin-Offs, Raymond Albert Hinerman
West Virginia Law Review
No abstract provided.
Taxation Of Foreign Incorporated Pocketbooks With Nonresident Alien Shareholders, William D. Popkin
Taxation Of Foreign Incorporated Pocketbooks With Nonresident Alien Shareholders, William D. Popkin
Articles by Maurer Faculty
No abstract provided.
When Will The Corporate Form Save Taxes?, Richard L. Strecker
When Will The Corporate Form Save Taxes?, Richard L. Strecker
Vanderbilt Law Review
While major emphasis will be placed upon the tax considerations involved in answering the question posed by the title, the broader problem is aptly stated in the familiar phrase, "Choice of Business Form."' It is not possible to consider this problem realistically without taking into account the context of the business and private law considerations which must enter into the decision, and may indeed be controlling over the tax factors. Therefore, the question, "When Will the Corporate Form Save Taxes?" will be discussed in the light of the full legal and business milieu.
A Comparison Of The Tax Consequences Of A Sale Of Good Will With A Covenant Not To Compete, William Walter Smith
A Comparison Of The Tax Consequences Of A Sale Of Good Will With A Covenant Not To Compete, William Walter Smith
West Virginia Law Review
No abstract provided.
The Solely-For-Voting-Stock Requirement In "B" Reorganizations Satisfied By Cash Payments For Fractional Shares-Mills V. Commissioner, Michigan Law Review
The Solely-For-Voting-Stock Requirement In "B" Reorganizations Satisfied By Cash Payments For Fractional Shares-Mills V. Commissioner, Michigan Law Review
Michigan Law Review
The Internal Revenue Code requires recognition of gains or losses realized upon a sale or exchange of property. An exception to this general rule is found in section 354(a)(1), the basic nonrecognition provision for stock-for-stock reorganizations. This section provides that a stockholder need not recognize gains or losses "if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization." However, before section 354 can be reached, the exchange must satisfy one of the …
Election Of Tax Free Intercorporate Dividends Under The Revenue Act Of 1964, Sheldon S. Cohen
Election Of Tax Free Intercorporate Dividends Under The Revenue Act Of 1964, Sheldon S. Cohen
William & Mary Law Review
No abstract provided.
Book Review Of Corporate Tax Management, Emeric Fischer
Book Review Of Corporate Tax Management, Emeric Fischer
William & Mary Law Review
No abstract provided.
Section 341(D) And (E)- A Journey Into Never-Never Land, William M. Goldstein
Section 341(D) And (E)- A Journey Into Never-Never Land, William M. Goldstein
Villanova Law Review (1956 - )
No abstract provided.
Federal Tax Aspects Of Non-Profit Organizations, Marcus Schoenfeld
Federal Tax Aspects Of Non-Profit Organizations, Marcus Schoenfeld
Villanova Law Review (1956 - )
No abstract provided.
Election, Operation And Termination Of A Subchapter S Corporation, Ronald R. Hrusoff
Election, Operation And Termination Of A Subchapter S Corporation, Ronald R. Hrusoff
Villanova Law Review (1956 - )
No abstract provided.
Personal Holding Companies And The Revenue Act Of 1964, Jerome B. Libin
Personal Holding Companies And The Revenue Act Of 1964, Jerome B. Libin
Michigan Law Review
By 1964, many years had elapsed since significant changes were made in the federal income tax treatment of so-called "personal holding companies." For that reason alone, any amendments contained in the Revenue Act of 1964 that dealt with personal holding companies would have deserved attention. But the fact is that the changes made by the 1964 Act are so powerful in their thrust that they require the most careful kind of study by every practitioner charged with advising closely held corporations. Since the new provisions are rather complicated in nature, such a study cannot lead to a full understanding of …
Election Of Tax Free Intercorporate Dividends Under The Revenue Act Of 1964, Sheldon S. Cohen
Election Of Tax Free Intercorporate Dividends Under The Revenue Act Of 1964, Sheldon S. Cohen
William & Mary Annual Tax Conference
No abstract provided.
Panel Discussion: Certain Problem Areas Under The Revenue Act Of 1964, Laurence N. Woodworth, Forrest W. Brown Jr., Hugh C. Stromswold, Thomas D. Terry, David O. Williams Jr.
Panel Discussion: Certain Problem Areas Under The Revenue Act Of 1964, Laurence N. Woodworth, Forrest W. Brown Jr., Hugh C. Stromswold, Thomas D. Terry, David O. Williams Jr.
William & Mary Annual Tax Conference
No abstract provided.
Corporations- Allocation Of Subsidiary's Tax Benefit From Consolidated Return, Thomas B. Ridgley
Corporations- Allocation Of Subsidiary's Tax Benefit From Consolidated Return, Thomas B. Ridgley
Michigan Law Review
Defendant parent corporation received from its subsidiary 3,556,992 dollars in tax benefits which had accrued to the subsidiary from filing a consolidated income tax return. By agreement between parent and subsidiary, the profit-making corporation was to pay the losing corporation the savings created by the consolidated return. The working relationship of the two assured the subsidiary profits and the parent losses. Consequently, nearly all tax benefit inevitably flowed to the parent. Plaintiffs, the subsidiary's minority stockholders, sought a refunding of benefits allocated to defendant, claiming that the agreement was unfair and alleging that the defendant, as the subsidiary's majority shareholder, …