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Articles 1021 - 1050 of 1180
Full-Text Articles in Tax Law
Redemptions Under Section 303, Emeric Fischer
Redemptions Under Section 303, Emeric Fischer
William & Mary Annual Tax Conference
No abstract provided.
Optional Adjustments To Basis Of Partnership Property On Transfer Of Partnership Interests, Donald J. Weidner
Optional Adjustments To Basis Of Partnership Property On Transfer Of Partnership Interests, Donald J. Weidner
William & Mary Annual Tax Conference
No abstract provided.
A New Look At The Section 119 Meals And Lodging Exclusion, Steven Luby
A New Look At The Section 119 Meals And Lodging Exclusion, Steven Luby
West Virginia Law Review
One of the most problematic areas of income tax law has been the excludability of various employee fringe benefits from taxable income. This article examines the appropriate tax treatment of one type of fringe benefit-meals furnished by an employer to his employee. Prior to 1954 the excludability of the value of meals furnished by an employer was dependent upon whether the factual circumstances of the case satisfied a "convenience of the employer" rule developed by administrative rulings and case law. In 1954 Congress attempted to end the confusion surrounding the excludability of meals furnished by an employer by enacting section …
Liabilities In Excess Of Basis: Focht, Section 357(C)(3) And The Assignment Of Income, Glenn E. Coven
Liabilities In Excess Of Basis: Focht, Section 357(C)(3) And The Assignment Of Income, Glenn E. Coven
Faculty Publications
No abstract provided.
The Constitutional Rights Of Corporations Revisited: Social And Political Expression And The Corporation After First National Bank V. Bellotti, Charles O'Kelley
The Constitutional Rights Of Corporations Revisited: Social And Political Expression And The Corporation After First National Bank V. Bellotti, Charles O'Kelley
Faculty Articles
The Supreme Court has addressed only a few occasions the extent to which corporations enjoy those constitutional rights so fundamental to private citizens. In this article Professor O'Kelley discusses the inherent difficulty in applying familiar constitutional principles to corporations and examines those cases in which the Supreme Court has either extended or denied to corporations various constitutional rights. Finding that two underlying conceptual doctrines -- the Field rational and the associational rationale -- have guided the Court in previous decisions in this area, he then applies these doctrines in an analysis of the recent Supreme Court decision in First National …
Choice Of Entities For Holding Real Estate: Corporations, Leonard L. Silverstein
Choice Of Entities For Holding Real Estate: Corporations, Leonard L. Silverstein
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entities For Holding Real Estate: Historical Structures And Low Income Housing, Bruce S. Lane
Choice Of Entities For Holding Real Estate: Historical Structures And Low Income Housing, Bruce S. Lane
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entities For Holding Real Estate: Real Estate Investment Trusts, John Schwieters
Choice Of Entities For Holding Real Estate: Real Estate Investment Trusts, John Schwieters
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entities For Holding Real Estate: Partnerships, Alan J.B. Aronsohn
Choice Of Entities For Holding Real Estate: Partnerships, Alan J.B. Aronsohn
William & Mary Annual Tax Conference
No abstract provided.
Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles
Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles
Vanderbilt Law Review
This Note first will set forth the Treasury Department's perception of the present abuses of tax shelter partnerships and will analyze existing procedural rules, the Treasury Department's proposed amendments, and the House of Representatives' proposed amendments in light of these abuses. Next, the Note will examine the substantive law of Subchapter K and will attempt to point out the probable effects of the proposed amendments on the aggregate concept of partnerships, on substantive partnership tax law, and on the viability of the partnership form of business. Finally, this Note will propose a solution to the problem of tax shelter partnership …
Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran
Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran
UIC Law Review
No abstract provided.
Tax Consequences For Corporate Divisions Of The Family Farm Corporation, Edwin T. Hood, John D. Shores, Charles S. Triplett
Tax Consequences For Corporate Divisions Of The Family Farm Corporation, Edwin T. Hood, John D. Shores, Charles S. Triplett
Faculty Works
No abstract provided.
Corporate Taxation - Net Operating Loss Carryovers Do Not Make Otherwise Worhtless Stock Valuable In The Hands Of The Corporate Shareholder, Jennifer Berke
Corporate Taxation - Net Operating Loss Carryovers Do Not Make Otherwise Worhtless Stock Valuable In The Hands Of The Corporate Shareholder, Jennifer Berke
Villanova Law Review (1956 - )
No abstract provided.
Tax Elections In Post Mortem Administration, John E. Donaldson
Tax Elections In Post Mortem Administration, John E. Donaldson
William & Mary Annual Tax Conference
No abstract provided.
Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee
Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee
Faculty Publications
Newly issued Proposed Regulations, under Section 355, follow recent decisions allowing horizontal divisions of a single business. In addition, the proposals introduce factors for determining whether a Section 355 transaction is a device for bailing out earnings" Mr. Lee analyzes these and other changes in the Proposed Regulations.
Pratt And Deductions For Payments To Partners, Donald J. Weidner
Pratt And Deductions For Payments To Partners, Donald J. Weidner
Scholarly Publications
No abstract provided.
Complete Stock Redemption In A Family Corporation: A Warning About The Pitfalls Of Two Standards, Eric T. Johnson
Complete Stock Redemption In A Family Corporation: A Warning About The Pitfalls Of Two Standards, Eric T. Johnson
Villanova Law Review (1956 - )
No abstract provided.
Close Corporations In Estate Planning After The Tax Reform Act Of 1976, Edwin T. Hood
Close Corporations In Estate Planning After The Tax Reform Act Of 1976, Edwin T. Hood
Faculty Works
No abstract provided.
Partnership Allocations And Tax Reform, Donald J. Weidner
Partnership Allocations And Tax Reform, Donald J. Weidner
Scholarly Publications
No abstract provided.
Eliminating The Capital Gains Preference. Part Ii: The Problem Of Corporate Taxation, Michael J. Waggoner
Eliminating The Capital Gains Preference. Part Ii: The Problem Of Corporate Taxation, Michael J. Waggoner
Publications
No abstract provided.
A Different Look At The Taxation Of Corporate Distribution And Shareholder Gain, Charles O'Kelley
A Different Look At The Taxation Of Corporate Distribution And Shareholder Gain, Charles O'Kelley
Faculty Articles
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code which has fostered a seemingly never-ending yet never-successful attempt by the Courts and Congress to design a coherent, non-discriminatory regime. In this article, Professor O'Kelley sets forth a proposal for a logical system for treating corporate distributions to shareholders which would strengthen the double tax scheme, and eliminate its present loopholes.
Eliminating The Capital Gains Preference. Part I: The Problems Of Inflation, Bunching And Lock-In, Michael J. Waggoner
Eliminating The Capital Gains Preference. Part I: The Problems Of Inflation, Bunching And Lock-In, Michael J. Waggoner
Publications
No abstract provided.
Compensating The Promoter-General Partner, Martin B. Cowan
Compensating The Promoter-General Partner, Martin B. Cowan
William & Mary Annual Tax Conference
No abstract provided.
Collapsible Partnerships, Michael S. Applebaum
Collapsible Partnerships, Michael S. Applebaum
William & Mary Annual Tax Conference
No abstract provided.
Constructive Cash Distributions, John W. Lee
Constructive Cash Distributions, John W. Lee
William & Mary Annual Tax Conference
No abstract provided.
The Corporate General Partner In A Limited Partnership, Henry Weiler
The Corporate General Partner In A Limited Partnership, Henry Weiler
William & Mary Annual Tax Conference
No abstract provided.
Initial Pitfalls Associated With Use Of The Limited Partnership, Michael T. Madison
Initial Pitfalls Associated With Use Of The Limited Partnership, Michael T. Madison
William & Mary Annual Tax Conference
No abstract provided.
State Taxation Of Interstate Business And The Supreme Court, 1974 Term: Standard Pressed Steel And Colonial Pipeline, Walter Hellerstein
State Taxation Of Interstate Business And The Supreme Court, 1974 Term: Standard Pressed Steel And Colonial Pipeline, Walter Hellerstein
Scholarly Works
It was an item of more than routine interest when the Supreme Court, late in the 1973 term, noted probable jurisdiction in two cases raising issues of central importance with respect to state tax power over interstate business. Standard Pressed Steel Co. v. Department of Revenue presented critical questions concerning due process and commerce clause limitations on a state's power to impose an unapportioned gross receipts tax on an interstate vendor; Colonial Pipeline Co. v. Traigle posed the recurring and unresolved question of the scope and vitality of the doctrine that the “privilege” of doing interstate business is immune from …
The Tax Shelter: A Reappraisal, 10 J. Marshall J. Prac. & Proc. 67 (1976), Fred A. Little, Fred Dasner
The Tax Shelter: A Reappraisal, 10 J. Marshall J. Prac. & Proc. 67 (1976), Fred A. Little, Fred Dasner
UIC Law Review
No abstract provided.
Recent Tax Court Case Suggests Expanded Use Of Multiple Corporations, Edwin T. Hood
Recent Tax Court Case Suggests Expanded Use Of Multiple Corporations, Edwin T. Hood
Faculty Works
No abstract provided.