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Articles 61 - 90 of 91
Full-Text Articles in Tax Law
Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon
Purchase And Sale Of Interests; Asset And Stock Acquisitions; Redemptions; And Terminations In Pass-Through Entities, Richard A. Shaw, Michael G. Frankel, Mary L. Harmon
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments Affecting Real Estate And Partnerships, Stefan F. Tucker
Recent Developments Affecting Real Estate And Partnerships, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Rolling Down The Curtain On "Roll-Ups": The Case For Federal Legislation To Protect Limited Partners, Kenneth R. Hillier
Rolling Down The Curtain On "Roll-Ups": The Case For Federal Legislation To Protect Limited Partners, Kenneth R. Hillier
Michigan Law Review
This Note examines roll-ups and the lack of alternatives available to reluctant limited partners. Part I focuses on existing judicial remedies for limited partners, such as injunctions and actions for damages, and explains why these courses of action provide inadequate protection. This Part then reviews recent attempts at statutory protection and points out the shortcomings of these remedies. Part II examines safeguards afforded analogously situated corporate shareholders and sets forth arguments why limited partners should receive similar protection. After demonstrating the need for legislation, Part III suggests a workable structure for this statutory protection. Then, the Note discusses the relative …
Using Partnerships As Acquisition Vehicles, Mark J. Silverman
Using Partnerships As Acquisition Vehicles, Mark J. Silverman
William & Mary Annual Tax Conference
No abstract provided.
Planning Considerations For Like-Kind Exchanges Involving Partnerships, Joseph G. Howe Iii
Planning Considerations For Like-Kind Exchanges Involving Partnerships, Joseph G. Howe Iii
William & Mary Annual Tax Conference
No abstract provided.
Allocating Partnership Liabilities Under The New Section 752 Regulations, William F. Nelson
Allocating Partnership Liabilities Under The New Section 752 Regulations, William F. Nelson
William & Mary Annual Tax Conference
No abstract provided.
Termination Of Partnerships And Of Partnership Interests, Louis A. Mezzullo
Termination Of Partnerships And Of Partnership Interests, Louis A. Mezzullo
William & Mary Annual Tax Conference
No abstract provided.
Partnership Operations And Distributions, Steven M. Friedman
Partnership Operations And Distributions, Steven M. Friedman
William & Mary Annual Tax Conference
No abstract provided.
Disguised Sales Between Partners And Partnerships: Section 707 And The Forthcoming Regulations, Karen C. Burke
Disguised Sales Between Partners And Partnerships: Section 707 And The Forthcoming Regulations, Karen C. Burke
Indiana Law Journal
No abstract provided.
Entity Classification And Integration: Publicly Traded Partnerships, Personal Service Corporations And The Tax Legislative Process, John W. Lee
Faculty Publications
No abstract provided.
Choice Of Entity: C Corporation Versus Pass Through Entities, Gail Levin Richmond
Choice Of Entity: C Corporation Versus Pass Through Entities, Gail Levin Richmond
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entity: Pass Through Entities, John W. Lee
Choice Of Entity: Pass Through Entities, John W. Lee
William & Mary Annual Tax Conference
No abstract provided.
An Aggregate Approach To Indirect Exchanges Of Partnership Interests: Reconciling Section 1031 And Subchapter K, Karen C. Burke
An Aggregate Approach To Indirect Exchanges Of Partnership Interests: Reconciling Section 1031 And Subchapter K, Karen C. Burke
UF Law Faculty Publications
This article examines indirect exchanges of partnership interests in light of the distinctive continuity-of-investment principles of section 1031 and Subchapter K of the Internal Revenue Code. Part II of the article focuses on the failure of judicial responses and alternative approaches prior to the 1984 Act to prevent the potential abuses of direct exchanges of partnership interests. Part III examines section 1031(a)(2)(D) against the background of two recent decisions by the United States Court of Appeals for the Ninth Circuit concerning successive tax-free exchanges. Part IV focuses on planning techniques involving like-kind exchanges coupled with partnership contributions and distributions. Part …
The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom
The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom
William & Mary Annual Tax Conference
No abstract provided.
The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven
The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven
William & Mary Annual Tax Conference
No abstract provided.
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Articles
If several persons wish to join together in a common enterprise in order to pool their capital or labor or some of each, they may choose among a variety of available organizational structures that will serve that purpose. The most common entity forms are partnerships (including joint ventures), corporations, and trusts. While, in its typical structure, each of those entity forms has its own distinct characteristics, the structure of such organizations often is modified by agreement so as to adopt attributes of another type of entity. Because of this, the substantive distinction between entity types is blurred.
Death Or Retirement Of A Partner, Stefan F. Tucker
Death Or Retirement Of A Partner, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Income And Estate Tax Planning With Subchapter S Corporations, Robert J. Hipple, Barbara C. Hipple
Income And Estate Tax Planning With Subchapter S Corporations, Robert J. Hipple, Barbara C. Hipple
William & Mary Annual Tax Conference
No abstract provided.
Partnerships And At Risk Problems, Stefan F. Tucker
Partnerships And At Risk Problems, Stefan F. Tucker
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.
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.
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.
Partnership Allocations, Donald J. Weidner
Partnership Allocations, Donald J. Weidner
William & Mary Annual Tax Conference
No abstract provided.
Tax Planning For Compensation Of Service Partners
Tax Planning For Compensation Of Service Partners
William & Mary Law Review
No abstract provided.
Pre-Operating Expenses And Section 174: Will "Snow" Fall?, John W. Lee
Pre-Operating Expenses And Section 174: Will "Snow" Fall?, John W. Lee
Faculty Publications
No abstract provided.
Comparison Of Major Tax And Legal Advantages Of Operating In An Unincorporated Form, Douglas A. Kahn
Comparison Of Major Tax And Legal Advantages Of Operating In An Unincorporated Form, Douglas A. Kahn
Book Chapters
As an introduction to the subject of this conference, several topics will be discussed. First, the tax and non-tax consequences of conducting business in a partnership form will be examined and compared with the consequences of doing business in a corporate form. The principle concern of this paper, however, is to examine the tax consequences of transferring property to a corporation, whether such transfer is made at the time the corporation is organized or at some subsequent date.
The Drafting Of Partnership Agreements Under The 1954 Internal Revenue Code, Robert S. Ashby, Albert L. Rabb Jr.
The Drafting Of Partnership Agreements Under The 1954 Internal Revenue Code, Robert S. Ashby, Albert L. Rabb Jr.
Indiana Law Journal
No abstract provided.
Income Tax Consequences Of Partnership Agreements Under The 1954 Internal Revenue Code, Earle B. Fowler, James T. Carey
Income Tax Consequences Of Partnership Agreements Under The 1954 Internal Revenue Code, Earle B. Fowler, James T. Carey
Kentucky Law Journal
No abstract provided.
Some Income Tax Aspects Of Community Property Law, Paul R. Trigg, Jr.
Some Income Tax Aspects Of Community Property Law, Paul R. Trigg, Jr.
Michigan Law Review
The recent enactment of community property law in Michigan and other states has created new problems for lawyers. Not the least of these is the question of the income tax consequences which flow from the existence of a community between the spouses. Nor is this the type of problem which can be shrugged off by reference to tax counsel. Local community property law and federal .income tax law are too closely enmeshed to be intelligently divided. No authority is needed for the statement that recently enacted community property laws are a product of high surtaxes. At the same time, these …