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Articles 901 - 930 of 1180
Full-Text Articles in Business Organizations Law
Choice Of Entity: S Corporations And Limited Liability Companies, Samuel P. Starr
Choice Of Entity: S Corporations And Limited Liability Companies, Samuel P. Starr
William & Mary Annual Tax Conference
No abstract provided.
Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon
Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon
William & Mary Annual Tax Conference
No abstract provided.
Selected Issues In Operating An S Corporation, Thomas P. Rohman
Selected Issues In Operating An S Corporation, Thomas P. Rohman
William & Mary Annual Tax Conference
No abstract provided.
Planning With S Corporations, Richard A. Shaw
Planning With S Corporations, Richard A. Shaw
William & Mary Annual Tax Conference
No abstract provided.
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 1), John W. Lee
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 1), John W. Lee
Faculty Publications
In this article, Lee charts two alternative methods for implementing an aggregate solution to the problem of partnership profits share exchanged for services. The functional, or judicial, method, he explains, is to handle (1) the exchange of partner-capacity services for a profit share subject to the risk of the venture with the Culbertson "common law relation of partnership," nonrealization event doctrine, implicitly contemplated by the 1984 legislative history to section 707(a)(2); (2) the classic Diamond transitory partner with a substance-over-form rule or step-transaction rule; and (3) a sale of the partnership interest in circumstances that would result in ordinary income …
Section 338 And Its Foolish Consistency Rules - The Hobgoblin Of Little Minds, Douglas A. Kahn
Section 338 And Its Foolish Consistency Rules - The Hobgoblin Of Little Minds, Douglas A. Kahn
Articles
The purposes of this Article are to examine whether there is any longer a reason for concern because a target corporation can choose selected assets for nonrecognition and to what extent the 1994 regulations properly deal with potentially abusive circumventions of tax goals. Before examining the current status of the consistency requirements, the historical background that led to the adoption of Section 338 and the operation of the section is discussed. The historical background includes: the judicially created Kimbell-Diamond rule, the codification and modification of that rule by the old version of Section 334(b)(2), the operation of the old version …
A Step In The Right Direction: Washington Passes The Limited Liability Company Act, Jessica A. Eaves
A Step In The Right Direction: Washington Passes The Limited Liability Company Act, Jessica A. Eaves
Seattle University Law Review
This Article describes how and why the LLC Act was passed, and provides a general outline of the LLC form in Washington. Section II outlines the perceived barriers to operating a business in Washington state. Section III sets out a brief legislative history of the Act, including the attempts by the Washington State Trial Lawyers Association to block the legislation, and proposed amendments to the legislation. Section IV describes the specifics of the LLC entity by reference to the Washington Limited Liability Company Act. Section IV also presents the comparative advantages of LLCs to other business forms. Finally, Section V …
The Forgotten Link: Control In Section 482, Wayne M. Gazur
The Forgotten Link: Control In Section 482, Wayne M. Gazur
Publications
The foundation of international taxable income allocations between related parties is formed by the imposition of an arm's length standard. The presence of "control" over a person invokes this measure. The author examines the implications of control presented by continuing developments in the global business environment, including the rise of cooperative interfirm arrangements.
Qualified Employee Benefit Plans - Legislation, Regulation And Compliance, Thomas D. Terry
Qualified Employee Benefit Plans - Legislation, Regulation And Compliance, Thomas D. Terry
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entity, Peter L. Faber
Choice Of Entity, Peter L. Faber
William & Mary Annual Tax Conference
No abstract provided.
Changing Places: Tax Treatment Of Changes In Choice Of Entity, Richard M. Lipton
Changing Places: Tax Treatment Of Changes In Choice Of Entity, Richard M. Lipton
William & Mary Annual Tax Conference
No abstract provided.
Formation And Operation Of The Limited Liability Company: Substantive Tax Issues, Allan G. Donn
Formation And Operation Of The Limited Liability Company: Substantive Tax Issues, Allan G. Donn
William & Mary Annual Tax Conference
No abstract provided.
State Taxation Of Corporate Income From Intangibles: Allied-Signal And Beyond, Walter Hellerstein
State Taxation Of Corporate Income From Intangibles: Allied-Signal And Beyond, Walter Hellerstein
Scholarly Works
If the field of state taxation has become somewhat of an academic backwater, it is not for want of issues warranting sustained scholarly attention. The Supreme Court alone has provided ample grist for the academic mill by handing down an extraordinary number of significant decisions delineating the federal constitutional restraints on state tax power. Among the state tax questions considered by the Court in recent years, none has figured so prominently and persistently in its deliberations as the states' power to tax the income of multijurisdictional corporations. In Allied-Signal, Inc. v. Director, Division of Taxation, the Court revisited the most …
Corporate Tax Policy For The Twenty-First Century: Integration And Redeeming Social Value, Glenn E. Coven
Corporate Tax Policy For The Twenty-First Century: Integration And Redeeming Social Value, Glenn E. Coven
Faculty Publications
No abstract provided.
Corporate Tax Policy For The Twenty-First Century: Integration And Redeeming Social Value , Glenn E. Coven
Corporate Tax Policy For The Twenty-First Century: Integration And Redeeming Social Value , Glenn E. Coven
Washington and Lee Law Review
No abstract provided.
The Future Of Partnership Taxation, Edward J. Schnee
The Future Of Partnership Taxation, Edward J. Schnee
Washington and Lee Law Review
No abstract provided.
The Merger Puzzle, John A. Miller
Section 902 Is Too Generous, George Mundstock
Employee Benefits Up-Date: Coping With Chaos, Mark S. Dray
Employee Benefits Up-Date: Coping With Chaos, Mark S. Dray
William & Mary Annual Tax Conference
No abstract provided.
Alternatives To Buy-Sell Agreements And Business Succession Planning, Myron E. Sildon
Alternatives To Buy-Sell Agreements And Business Succession Planning, Myron E. Sildon
William & Mary Annual Tax Conference
No abstract provided.
Buy-Sell Agreements For The Family Owned Business: Practical Considerations And Planning Opportunities, Morton A. Harris
Buy-Sell Agreements For The Family Owned Business: Practical Considerations And Planning Opportunities, Morton A. Harris
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments Affecting Real Estate And Partnerships, Stefan F. Tucker
Recent Developments Affecting Real Estate And Partnerships, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Intangible Asset Depreciation: Newark And Section 197, Kenneth W. Gideon
Intangible Asset Depreciation: Newark And Section 197, Kenneth W. Gideon
William & Mary Annual Tax Conference
No abstract provided.
The Final Regulations Under Irc Sections 704(B) And 752: Envisioning Economic Risk Of Loss Through A Glass Darkly, Ed R. Haden
The Final Regulations Under Irc Sections 704(B) And 752: Envisioning Economic Risk Of Loss Through A Glass Darkly, Ed R. Haden
Washington and Lee Law Review
No abstract provided.
Taxation Of Business Rent, George Mundstock
University Of Richmond Law Review
University Of Richmond Law Review
University of Richmond Law Review
No abstract provided.
Subchapter S: Operational Issues, Peter L. Faber
Subchapter S: Operational Issues, Peter L. Faber
William & Mary Annual Tax Conference
No abstract provided.
S Corporation Stock In Trusts And Estates - Preserving The S Election And Other Practical Problems, W. Birch Douglass Iii
S Corporation Stock In Trusts And Estates - Preserving The S Election And Other Practical Problems, W. Birch Douglass Iii
William & Mary Annual Tax Conference
No abstract provided.
Planning Opportunities After Chapter 14 (Section 2701 And 2702), Frederic A. Nicholson
Planning Opportunities After Chapter 14 (Section 2701 And 2702), Frederic A. Nicholson
William & Mary Annual Tax Conference
No abstract provided.
Changing The World Economies: A Model For Applying United States Countervailing Duty Law To Exported Products From A Unified Germany, 25 J. Marshall L. Rev. 81 (1991), Charles P. Romaker
Changing The World Economies: A Model For Applying United States Countervailing Duty Law To Exported Products From A Unified Germany, 25 J. Marshall L. Rev. 81 (1991), Charles P. Romaker
UIC Law Review
No abstract provided.