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Articles 811 - 840 of 1180

Full-Text Articles in Business Organizations Law

Representing The Failing Company Where The Irs Is "Knocking On The Door", Craig D. Bell, T. Keith Fogg, George C. Gretes, Nina E. Olson Nov 2001

Representing The Failing Company Where The Irs Is "Knocking On The Door", Craig D. Bell, T. Keith Fogg, George C. Gretes, Nina E. Olson

William & Mary Annual Tax Conference

No abstract provided.


Why The Corporate Amt Should Be Retained, Reuven S. Avi-Yonah Nov 2001

Why The Corporate Amt Should Be Retained, Reuven S. Avi-Yonah

Articles

The corporate AMT is under attack. Repeal has been proposed by the White House, endorsed by the ABA/AICPA/TEI tax simplification project, and included in the stimulus bill passed by the House of Representatives. Repeal is supported on two principal grounds: That the corporate AMT increases complexity, and that it is pro-cyclical.


Bad Medicine: Erisa's Equitable Remedies And The Preemption Of Fundamental Legal Rights, 34 J. Marshall L. Rev. 583 (2001), Marilyn Lablaiks Jan 2001

Bad Medicine: Erisa's Equitable Remedies And The Preemption Of Fundamental Legal Rights, 34 J. Marshall L. Rev. 583 (2001), Marilyn Lablaiks

UIC Law Review

No abstract provided.


Prohibiting The Deduction For Non-Corporate Tax Deficiency Interest: When Treasury Goes Too Far, 34 J. Marshall L. Rev. 557 (2001), William G. Andreozzi Jan 2001

Prohibiting The Deduction For Non-Corporate Tax Deficiency Interest: When Treasury Goes Too Far, 34 J. Marshall L. Rev. 557 (2001), William G. Andreozzi

UIC Law Review

No abstract provided.


Anatomy Of Valuing Stock In Closely Held Corporations: Pursuing The Phantom Of Objectivity Into The New Millennium, Stephen J. Leacock Jan 2001

Anatomy Of Valuing Stock In Closely Held Corporations: Pursuing The Phantom Of Objectivity Into The New Millennium, Stephen J. Leacock

Faculty Scholarship

No abstract provided.


Frictions As A Constraint On Tax Planning, David M. Schizer Jan 2001

Frictions As A Constraint On Tax Planning, David M. Schizer

Faculty Scholarship

The government often uses narrow tax reforms to target specific planning strategies. Sometimes the targeted transaction is stopped. But in other cases, taxpayers press on, tweaking the deal just enough to sidestep the reform. The difference often lies in transaction costs, financial accounting, and other 'frictions, " which are constraints on tax planning external to the tax law.

This Article contributes a methodology for determining whether frictions will block end runs, and illustrates the effect of frictions by comparing the constructive sale rule of section 1259 with the constructive ownership rule of section 1260. These reforms use the same statutory …


Taxation Of Distributions: Distributions From Partnerships And Limited Liability Companies, David W. Larue Dec 2000

Taxation Of Distributions: Distributions From Partnerships And Limited Liability Companies, David W. Larue

William & Mary Annual Tax Conference

No abstract provided.


Enterprise Risk Management: Realizing Profit From Risk, Raymond M. Slabaugh Dec 2000

Enterprise Risk Management: Realizing Profit From Risk, Raymond M. Slabaugh

William & Mary Annual Tax Conference

No abstract provided.


Valuations In The Business Setting: International Glossary Of Business Valuation Terms Dec 2000

Valuations In The Business Setting: International Glossary Of Business Valuation Terms

William & Mary Annual Tax Conference

No abstract provided.


Valuations In The Business Setting: Exhibits Dec 2000

Valuations In The Business Setting: Exhibits

William & Mary Annual Tax Conference

No abstract provided.


Valuations In The Business Setting, Harold G. Martin Jr. Dec 2000

Valuations In The Business Setting, Harold G. Martin Jr.

William & Mary Annual Tax Conference

No abstract provided.


State Challenges To Related Party Transactions, D. French Slaughter Iii Dec 2000

State Challenges To Related Party Transactions, D. French Slaughter Iii

William & Mary Annual Tax Conference

No abstract provided.


Who Spilled Coke On My Laptop?, D. French Slaughter Iii Dec 2000

Who Spilled Coke On My Laptop?, D. French Slaughter Iii

William & Mary Annual Tax Conference

No abstract provided.


Choice Of Small Business Tax Entity, John W. Lee Apr 2000

Choice Of Small Business Tax Entity, John W. Lee

Faculty Publications

This article summarizes parts of Lee’s forthcoming article “A Populist Political Perspective of the Business Tax Entities Universe: Hey the Stars Might Lie But the Numbers Never Do,” 78 Texas L. Rev. 885 (2000). Conventional wisdom, says Lee, holds that the LLC, due to its limited liability and hassle-free single level of taxation, will supplant C and S corporations as the choice of entity for new businesses. In fact, in most jurisdictions corporate formations outnumber LLC formations 2:1 or more, and IRS Statistics of Income (SOI) projects that the S corporation will be the fastest growing tax entity for 2000 …


Piercing The Corporate Veil To Recover Pension Payments: It's Time To Address The Issue, 33 J. Marshall L. Rev. 497 (2000), Nella Disanto Jan 2000

Piercing The Corporate Veil To Recover Pension Payments: It's Time To Address The Issue, 33 J. Marshall L. Rev. 497 (2000), Nella Disanto

UIC Law Review

No abstract provided.


Determining A Partner's Share On Unrealized Receivables At The Liquidation Of The Partner's Interest, Stephen Utz Jan 2000

Determining A Partner's Share On Unrealized Receivables At The Liquidation Of The Partner's Interest, Stephen Utz

Faculty Articles and Papers

Partnership law allows partners great freedom to vary the terms on which they share partnership profits from different sources. Partnership tax law, however, seems to presume, for purposes of the collapsible partner rules, that partners will share the revenue from the collection of receivables always in proportion to the value of their partnership interests. This counterfactual presumption exposes both the government and partner/taxpayers to unfortunate consequences. A substance-over-form approach to the attribution of unrealized receivables would certainly be unworkable, because too costly and intrusive to administer. Something between substance-over form and form-over-substance would best implement the policy of Subchapter K …


Cash Balance Plans: They Work For Employers But Do They Work For Employees?, 34 J. Marshall L. Rev. 345 (2000), Deana Saxinger Jan 2000

Cash Balance Plans: They Work For Employers But Do They Work For Employees?, 34 J. Marshall L. Rev. 345 (2000), Deana Saxinger

UIC Law Review

No abstract provided.


A Populist Political Perspective Of The Business Tax Entities Universe: Hey The Stars Might Lie, But The Numbers Never Do, John W. Lee Jan 2000

A Populist Political Perspective Of The Business Tax Entities Universe: Hey The Stars Might Lie, But The Numbers Never Do, John W. Lee

Faculty Publications

No abstract provided.


Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch Jan 2000

Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch

LLM Theses and Essays

The instant thesis is organized in three main parts. The first contains an overview of U.S. law including constitutional issues of the topic focusing on the separation of tax powers between federal and state authorities with special attention to the basis and extent to which a State is entitled to impose levies on business organizations; a brief analysis of federal legislation allowing the pass-through regime; and summary concerning LLC legislation in the States. The second analyzes the application of the main, basic principles of international taxation (such as residence, source rules, application of international treaties, and connected with it the …


University Of Richmond Law Review Jan 2000

University Of Richmond Law Review

University of Richmond Law Review

No abstract provided.


Corporate Finance, Corporate Law And Finance Theory, Peter H. Huang, Michael S. Knoll Jan 2000

Corporate Finance, Corporate Law And Finance Theory, Peter H. Huang, Michael S. Knoll

Publications

No abstract provided.


The Conundrum Of Executive Compensation, Mark J. Loewenstein Jan 2000

The Conundrum Of Executive Compensation, Mark J. Loewenstein

Publications

Much of the scholarship on executive compensation that appears in law reviews assumes that large U.S. corporations overpay their chief executive officers ("CEOs"). This assumption is understandable, as many of these compensation packages are indeed stunning. The question of whether CEOs are overpaid, however, is complicated. Some scholars in other disciplines, principally in economics and management science, have studied the issue but, as this Article demonstrates, this literature does not confirm the assumption. Indeed, some studies suggest that CEO pay is competitive. Moreover, efforts to reduce the level of executive compensation may have the unintended consequence of achieving the opposite …


Taxable And Tax-Free Acquisitions And Separations, Mark J. Silverman, Robert H. Wellen, Mark L. Yecies Dec 1999

Taxable And Tax-Free Acquisitions And Separations, Mark J. Silverman, Robert H. Wellen, Mark L. Yecies

William & Mary Annual Tax Conference

No abstract provided.


Selected Current Developments In Financial Accounting And Reporting, David W. Larue Dec 1999

Selected Current Developments In Financial Accounting And Reporting, David W. Larue

William & Mary Annual Tax Conference

No abstract provided.


Capitalization In The Nineties, Glenn R. Carrington Dec 1999

Capitalization In The Nineties, Glenn R. Carrington

William & Mary Annual Tax Conference

No abstract provided.


Section 338(H)(10) & Appendix, Mark J. Silverman, Jonathan I. Forrest Dec 1999

Section 338(H)(10) & Appendix, Mark J. Silverman, Jonathan I. Forrest

William & Mary Annual Tax Conference

No abstract provided.


Use Of Limited Liability Companies In Corporate Transactions, Mark J. Silverman, Lisa M. Zarlenga Dec 1999

Use Of Limited Liability Companies In Corporate Transactions, Mark J. Silverman, Lisa M. Zarlenga

William & Mary Annual Tax Conference

No abstract provided.


Section 338(H)(10), Mark L. Yecies Dec 1999

Section 338(H)(10), Mark L. Yecies

William & Mary Annual Tax Conference

No abstract provided.


Contingent Consideration And Contingent Liabilities In Acquisitions: Outline,Addendum, References, Robert H. Wellen Dec 1999

Contingent Consideration And Contingent Liabilities In Acquisitions: Outline,Addendum, References, Robert H. Wellen

William & Mary Annual Tax Conference

No abstract provided.


Corporate Divisions Under Section 355, Mark J. Silverman Dec 1999

Corporate Divisions Under Section 355, Mark J. Silverman

William & Mary Annual Tax Conference

No abstract provided.