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Articles 181 - 183 of 183
Full-Text Articles in Tax Law
Tax Significance Of Payments In Satisfaction Of Liabilities Arising Under Section 16(B) Of The Securities Exchange Act Of 1934, Lawrence Lokken
Tax Significance Of Payments In Satisfaction Of Liabilities Arising Under Section 16(B) Of The Securities Exchange Act Of 1934, Lawrence Lokken
Scholarly Works
This article examines the income tax significance to the insider of his payment in satisfaction of a liability arising under section 16(b). Such taxpayers have usually sought a deduction against ordinary income in the year of payment. When the issue was first raised, the deduction was denied. Section 16(b) liability was held to be in the nature of a penalty; allowance of the deduction, it was found, "would weaken an effective method of enforcing the sharply defined policy expressed in sectin 16(b)...." In 1961 the Internal Revenue Service modified its earlier position by ruling that section 16(b) is not a …
Tax Significance Of Payments In Satisfaction Of Liabilities Arising Under Section 16(B) Of The Securities Exchange Act Of 1934, Lawrence Lokken
Tax Significance Of Payments In Satisfaction Of Liabilities Arising Under Section 16(B) Of The Securities Exchange Act Of 1934, Lawrence Lokken
Georgia Law Review
IT is commonly believed that trading by a corporate officer or director, or other person close to the decision making processes of a corporation, in stock of the corporation can pose peculiar dangers and raise substantial questions of fairness, especially if such trading is speculative in nature. A corporate manager's investment in the shares of his company represents a personal financial commitment to the future of the company and admittedly is beneficial to all. Yet, when an insider speculates, his knowledge of corporate plans and affairs can give him an unfair advantage over other investors in timing his transactions so …
Sales Transactions And Income In Respect Of A Decedent, G. S. T.
Sales Transactions And Income In Respect Of A Decedent, G. S. T.
Georgia Law Review
An important' tax question arises when income is received by a decedent's successor in interest as a result of a sale transaction which had its origins in the decedent's lifetime activities but which was not consummated until after his death. The answer to be sought is whether or not the proceeds of the sale constitute income in respect of a decedent within the meaning of section 6913 of the Internal Revenue Code of 1954. If so, the successor in interest will include in gross income the same amount as the decedent would have included had he completed the sale and …