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Articles 91 - 94 of 94
Full-Text Articles in Business Organizations Law
The Western Hemisphere Trading Corporation; In Outline, Samuel Laderman
The Western Hemisphere Trading Corporation; In Outline, Samuel Laderman
Cleveland State Law Review
One of the last frontiers of effective tax reduction exists in the exporting field. This device was specifically created by Congress to enable American corporations trading in foreign countries within the Western Hemisphere to compete with foreign corporations and has been approved by the Commissioner of Internal Revenue. There is no federal law providing for the incorporation of Western Hemisphere Trade Corporations. The corporations are organized under applicable state law and qualify as Western Hemisphere Trade Corporations.
Discharge Of Corporate Indebtedness At Less Than Face Value Under The Internal Revenue Code, Harvey Mahlig
Discharge Of Corporate Indebtedness At Less Than Face Value Under The Internal Revenue Code, Harvey Mahlig
Cleveland State Law Review
Prior to 1939 whenever a corporation paid less than the face amount of an obligation in full satisfaction thereof, taxable income was realized to the extent of the difference. In 1939 paragraph (9) was added to Section 22 (b) of the InternalRevenue Code. Therein it was provided that there should not be included in the taxable income of a corporation the amount of income attributable to the discharge of any indebtedness as evidenced by a security, provided at the time of such discharge the corporation was in an unsound financial condition. In orderto obtain the relief provided, the corporation had …
Treasury Stock; A Corporate Anomaly, Harry Kotler
Treasury Stock; A Corporate Anomaly, Harry Kotler
Cleveland State Law Review
Treasury shares are an anomaly, since it has thus far appeared that they have been subjected to a doctrine of expediency, a doctrine of ascertaining their position and consequences only from the point of view of the specific problem at hand. They are assets for one purpose, but not assets for another. They are treated as existing for one purpose, but nonexistent for another. They appear, reappear and disappear. They have a fluidity which is uncommon in corporate law, where certainty, precision and definiteness are the keynotes. Because they offer to a corporation a singularly tempting opportunity to represent the …
Taxation; Deductibility Of Corporate Contributions To A Group Annuity Policy And An Employee's Trust, Daniel R. Mccarthy
Taxation; Deductibility Of Corporate Contributions To A Group Annuity Policy And An Employee's Trust, Daniel R. Mccarthy
Cleveland State Law Review
Discussion of Lincoln Electric Company v. Commissioner of Internal Revenue, 17 Tax Court 1600 (1952): The petitioner, a manufacturing company, paid the sum of $575,206.43 into a retirement annuity policy for its employees and contributed the sum of $1,000,000.00 to an employees' trust. Held: Such payments constituted ordinary and necessary business expenses and were deductible under section 23 (a) (1)(A) of the Internal Revenue Code.