Open Access. Powered by Scholars. Published by Universities.®

Tax Law Commons™

Open Access. Powered by Scholars. Published by Universities.®

Akron Tax Journal

Articles 151 - 160 of 160

Full-Text Articles in Tax Law

Assisting Dislocated Workers: Dimensions, Needs And Tax Policy Options, Lewis D. Solomon, Janet S. Solomon, Brian M. Malsberger Jan 1984

Assisting Dislocated Workers: Dimensions, Needs And Tax Policy Options, Lewis D. Solomon, Janet S. Solomon, Brian M. Malsberger

Akron Tax Journal

The involvement of the federal government in retraining of dislocated workers raises the specter of rigidity, bureaucracy, paternalism, and cost. After examining the dimensions of the dislocated worker problem and the need for governmental involvement, this article examines the use of tax policy to enable workers to bridge the gap between old and new jobs and to thrive in an economy in transition. The policy making challenge can be succinctly stated: is it possible to use the federal income tax system to the advantage of society by creating tax incentives for a retraining program based on individual choice and limited …

Go to article

Over The Back Fence: Tax Shelters And Other Sales Of Federal Income Tax Reductions, Thomas A. Robinson Jan 1984

Over The Back Fence: Tax Shelters And Other Sales Of Federal Income Tax Reductions, Thomas A. Robinson

Akron Tax Journal

Structural features of the federal income tax system frequently make the same tax reduction' more valuable to one taxpayer than to another. There are many types of such tax reductions (including deductions and credits), creating a fertile environment for the tax shelter markets. Black letter law says tax reductions are nontransferable. In other words, taxpayers are not allowed to sell their mortgage interest deductions over the back fence to their neighbors. Yet, observation reveals some transactions where tax reductions are in effect bought and sold. This article will examine four of these transactions: business sales, divorce agreements, sale-leasebacks, and partnership …

Go to article

Selling A Business And Starting Anew: Liquidation-Reincorporation In The Simple Situation, John R. Dorocak Jan 1984

Selling A Business And Starting Anew: Liquidation-Reincorporation In The Simple Situation, John R. Dorocak

Akron Tax Journal

A client approaches his attorney with a fairly common problem. The client, as sole or predominant shareholder, operates a business in the corporate form. He wishes to sell all the assets of that business to a third party. The client will then take the proceeds of the sale, after distribution to himself as shareholder, and use a part of them to capitalize a new corporation, which will purchase a new business. The question for the attorney is whether this simple transaction will ever call forth the tax doctrine of liquidation-reincorporation. This article will examine the likelihood of the liquidation reincorporation …

Go to article

Tax Consequences Of Purchases Of Computer Hardware And Software, Robert W. Malone Jan 1984

Tax Consequences Of Purchases Of Computer Hardware And Software, Robert W. Malone

Akron Tax Journal

The advent of the computer age has resulted in a significant increase in the investment by businesses in computer hardware and software. The term "hardware" refers to the physical equipment which accepts (input), processes, and prints (output) information received by it. The term "software" refers to the instructions (language) used to direct a computer to perform desired tasks and the documentation (discs, tapes, etc.) on which such instructions are recorded.' Examples of types of software include Basic, Fortran, Cobol, and RPG. This article addresses the tax aspects and planning opportunities associated with the purchases of computer hardware and software.

Go to article

Death Of A Partner: Pre And Post-Mortem Planning, Jerome Hesch Jan 1983

Death Of A Partner: Pre And Post-Mortem Planning, Jerome Hesch

Akron Tax Journal

There are several alternative techniques which can be employed to alleviate the income tax problems associated with the death of a partner. The sophisticated tax advisor will understand, however, that some of the suggested techniques may not be practical for all situations. The purpose of this article is to describe these planning techniques and to guide the tax advisor as to which technique is appropriate for his client.

Go to article

Proceedings From The 1983 Tax Institute Symposium: Corporate Asset And Corporate Stock Acquisitions, Harvey Frutkin Jan 1983

Proceedings From The 1983 Tax Institute Symposium: Corporate Asset And Corporate Stock Acquisitions, Harvey Frutkin

Akron Tax Journal

This article discusses corporate assets and corporate stock acquisitions. It looks at the choices and decisions that are involved in the purchase and sale of a business, including the purchase and sale of a corporation's stock and the corporation's assets. Those are the choices: the asset deal or the stock deal.

Go to article

Tax Equity And Fiscal Responsibility Act Of 1982, Merlin G. Briner Jan 1983

Tax Equity And Fiscal Responsibility Act Of 1982, Merlin G. Briner

Akron Tax Journal

O N AUGUST 20, 1982, President Reagan signed into law the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), the fourth piece of major tax legislation in less than seven years. Though TEFRA has been said to provide the single largest tax increase in American history, President Reagan lobbied for it not as a tax bill, but as a revenue measure which, to his mind, in no way represented a backing-off from his vaunted "supply side-trickle down" economic program. This article will discuss the implications of TERFA on both the individual taxpayer and businesses.

Go to article

Is The Will The Way? Transmitting Interests In A Family Corporation, Gail Levin Richmond Jan 1983

Is The Will The Way? Transmitting Interests In A Family Corporation, Gail Levin Richmond

Akron Tax Journal

This article examines the effects of recent enactments upon the methods of transmitting interests in a closely-held corporation. Because the tax consequences will frequently vary depending upon whether the corporation is a C corporation or an S corporation, a brief description of each form precedes the discussion of the relevant tax consequences. The tax consequences, which will be discussed thereafter, involve interrelated questions: which consequences are involved, and who will bear their brunt? Because nontax considerations also influence the timing of stock transfers, the discussion will address them as well.

Go to article

The Step-Transaction Doctrine In Subchapter C: The Search For A Unifying Theory Continues, Robert Willens Jan 1983

The Step-Transaction Doctrine In Subchapter C: The Search For A Unifying Theory Continues, Robert Willens

Akron Tax Journal

This article discusses the Step-Transaction Doctrine in Subchapter C of the Internal Revenue Code. It is generally conceded that the Doctrine can apply if it meets any of the three alternative tests: : the "end result" test, the "mutual interdependence" test, or the more restrictive "binding commitment" test. However, there is difficult in determining which test will apply to the particular transaction under scrutiny. This is explored through a review of decisions dealing with Section 302 which relates to redemptions; Section 351 which deals with corporate organization; Section 368 which governs corporate reorganizations; and finally, the "integrated transaction" doctrine under …

Go to article

Use Of Multiple Qualified Pension Plans By Small Employers After The Tax Equity And Fiscal Responsibility Act Of 1982, Daniel R. Sharpe Jan 1983

Use Of Multiple Qualified Pension Plans By Small Employers After The Tax Equity And Fiscal Responsibility Act Of 1982, Daniel R. Sharpe

Akron Tax Journal

Since the adoption of the Employee Retirement Income Security Act of 1974, many employers have adopted more than one pension or profit sharing plan for a variety of reasons. The rules governing the design and structure of multiple pension plans have remained relatively static since 1974 until the adoption of the Tax Equity and Fiscal Responsibility Act of 1982. This article will explore some of the radical changes made by TEFRA to the design and operation of multiple pension plans, particularly by small employers.

Go to article

First Prev