Tax Law Commons^™

Income And Estate Tax Planning With Subchapter S Corporations, Robert J. Hipple, Barbara C. Hipple

William & Mary Annual Tax Conference

No abstract provided.

Recent Developments Affecting Multiple Corporations: Sections 304, 306, And 338, James P. Holden

William & Mary Annual Tax Conference

No abstract provided.

Tax Considerations In Structuring Foreign Investment In The United States, Thomas H. Olsen

BYU Law Review

No abstract provided.

Section 356(A)(2): A Study Of Uncertainty In Corporate Taxation, William J. Rands

University of Miami Law Review

Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorganization to treat any gain recognized as a dividend, if the reorganization "has the effect of the distribution of a dividend." This article examines the conflicting interpretations of this section and offers suggested changes in the law. The article also reviews the performance of all three branches of government in developing tax law.

The Subchapter S Revision Act: An Analysis And Appraisal, Glenn E. Coven

Faculty Publications

No abstract provided.

Origins Of Tax Law: The History Of The Personal Service Corporation, J. Timothy Philipps, James S. Mcnider, Iii, Daniel E. Riley

Washington and Lee Law Review

No abstract provided.

United States V. Vogel Fertilizer Co. Harmonizing With Congress: The Court Requires The Treasury To Tune Up, 16 J. Marshall L. Rev. 601 (1983), Kenneth Kopicki

UIC Law Review

No abstract provided.

Partnership Level Proceedings: Policies, Procedures And Planning, Claudine Ausness

Kentucky Law Journal

No abstract provided.

Compliance Provisions Of Tax Equity And Fiscal Responsibility Act (Tefra), Charles Roddy

William & Mary Annual Tax Conference

No abstract provided.

The Future Of Personal Service Corporations: Is There Life After Tefra?, Converse Murdoch

William & Mary Annual Tax Conference

No abstract provided.

The Impact Of Tefra On Employee Benefits, Louis A. Mezzullo

William & Mary Annual Tax Conference

No abstract provided.

The Debt-Equity Regulations (Section 385), Felix B. Laughlin

William & Mary Annual Tax Conference

No abstract provided.

Planning For Disadvantaged Corporations, Paul Broderick

William & Mary Annual Tax Conference

No abstract provided.

Tefra: Purchase And Sale Of A Corporate Business, Martin D. Ginsburg

William & Mary Annual Tax Conference

No abstract provided.

State Income Taxation Of Multijurisdictional Corporations, Part Ii: Reflections On Asarco And Woolworth, Walter Hellerstein

Scholarly Works

The first part of this Article, "State Income Taxation of Multijurisdictional Corporations: Reflections on Mobil, Exxon, and H.R. 5076" [79 Mich. L. Rev. 113], did not contemplate a sequel. The Supreme Court's decisions last term in two state corporate income tax cases, however, created an irresistible opportunity to write one. The Court's opinions in ASARCO and Woolworth picked up where its opinions in Mobil and Exxon left off. Yet the direction taken by these more recent decisions veers sharply from the course ostensibly set by their predecessors. This Article will consider the Court's latest pronouncements in this area in a …

State Income Taxation Of Multijurisdictional Corporations, Part Ii: Reflections On Asarco And Woolworth, Walter Hellerstein

Scholarly Works

The first part of this Article, State Income Taxation of Multiurisdictional Corporations: Reflections on Mobil, Exxon, and H A 5076, did not contemplate a sequel. The Supreme Court's decisions last term in two state corporate income tax cases, however, created an irresistible opportunity to write one. The Court's opinions in ASARC0 and Woolworth picked up where its opinions in Mobil and Exxon left off. Yet the direction taken by these more recent decisions veers sharply from the course ostensibly set by their predecessors. This Article will consider the Court's latest pronouncements in this area in a continuing if quixotic effort …

The Bad Blood Factor And 302 Redemptions: A Retrospective Examination And Analysis, Joseph J. Miller

West Virginia Law Review

No abstract provided.

Capital Expenditures: A Result In Search Of A Rationale, John W. Lee, Nina R. Murphy

Faculty Publications

No abstract provided.

The Regulations Under Section 385: A Review, Evaluation, And Suggested Approach, Jesse V. Boyles, Randolph J. Rush

Villanova Law Review (1956 - )

No abstract provided.

Corporate Distributions And The Income Tax: A Consideration Of The Inconsistency Between Subchapter C And Its Underlying Policy, Charles R.T. O'Kelley

Scholarly Works

This Article suggests that although one part of a corporate distribution may be analogous to a sale and the remainder to a dividend, there is no overlap of, or competition between, analogies. This lack of overlap is apparent when one realizes that a dividend and a sale are methods of realizing different types of gain, rather than alternative methods of realizing the same type of gain. This Article examines the basic conceptual model underlying the present system of taxing corporate distributions, describes the appropriate treatment of corporate distributions that is suggested by an understanding of the underlying concepts, and indicates …

Professional Corporations - Practical Problems And Solutions, K. Maxwell Dale

William & Mary Annual Tax Conference

No abstract provided.

Equipment Leasing, Robert S. Parker Jr.

William & Mary Annual Tax Conference

No abstract provided.

Partnerships And At Risk Problems, Stefan F. Tucker

William & Mary Annual Tax Conference

No abstract provided.

State Income Taxation Of Multijurisdictional Corporations: Reflections On Mobil, Exxon, And H.R. 5076, Walter Hellerstein

Scholarly Works

The state tax field is experiencing a renaissance of sorts. The Supreme court has displayed a renewed interest in the area, handing down an unusual number of significant decisions addressed to the constitutional restraints on state tax power. State courts have exhibited a similar revival of interest in these problems through an outpouring of uncharacteristically thoughtful opinions concerning state taxation of multistate and multinational enterprise. Congress, whose concern with state taxation of interstate and foreign commerce has been sporadic, is again considering legislation that would limit state taxing authority in these domains. Even the executive branch, which seldom intervenes in …

State Income Taxation Of Multijurisdictional Corporations: Reflections On Mobil, Exxon, And H.R. 5076, Walter Hellerstein

Scholarly Works

The state tax field is enjoying a renaissance of sorts. The Supreme Court has displayed a renewed interest in the area, handing down an unusual number of significant decisions addressed to the constitutional restraints on state tax power. State courts have exhibited a similar revival of interest in these problems through an out-pouring of uncharacteristically thoughtful opinions concerning state taxation of multistate and multinational enterprise. Congress, whose concern with state taxation of interstate and foreign commerce has been sporadic, is again considering legislation that would limit state taxing authority in these domains.

Even the executive branch, which seldom intervenes in …

Introduction: The Value-Added Tax - A Symposium, Edwin T. Hood

Faculty Works

On October 22, 1979, Representative Al Ullman, Chairman of the House Ways and Means Committee, introduced H.R. 5665, the Tax Restructuring Act of 1979. Representative Ullman proclaimed the bill, which contains a ten percent value-added tax, as the "largest adjustment in U.S. taxation since 1913." In his statement accompanying the introduction of H.R. 5665, Chairman Ullman states that the overall purpose for the imposition of a value-added tax coupled with reductions in social security and income taxes, is to correct major flaws in the United States economy-namely double digit inflation, declining productivity, inadequate capital formation, and lag­ging competition with foreign …

Transfers Of Partnership Interests And Optional Adjustments To Basis, Donald J. Weidner

Scholarly Publications

In 1954, Congress enacted the first comprehensive statutory treatment of partners and partnerships in an attempt to clarify and simplify an area of the law it considered strikingly confused. A quarter of a century later, much confusion and complexity continues and must be dealt with by practitioners who do not have the luxury of specializing in tax, much less in partnership tax. The rules on optional adjustments to basis are particularly perplexing to many attorneys because they involve the accounting function, often foreign to the lawyer's training and talents, and often performed with heavy reliance on another profession. The two …

Use Of The Tax-Free Triangular Merger For The Acquisition Of Two Corporations With Cross-Ownership, 14 J. Marshall L. Rev. 33 (1980), Theodore W. Grippo

UIC Law Review

No abstract provided.

Double Jeopardy Of Corporate Profits, The , Constantine N. Katsoris

Faculty Scholarship

The more one reads about our economy, the more one is baffled and alarmed. Permanent solutions to economic problems are elusive. Treating one financial malaise often aggravates another sector of the economy, necessitating a delicate balancing of conflicting interests. Furthermore, the problems are complicated by the constant influence of foreign forces. Nevertheless, most economists agree that any solution will require enormous funding. Unfortunately, the public has little, if any, confidence in our tax system. Indeed, some tax laws and proposals have been referred to as "obscene" and a "disgrace to the human race." Few quarrel with the aptness of such …

Estate Planning For Subchapter S Corporation Stock, Barbara B. Hipple

William & Mary Annual Tax Conference

No abstract provided.