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Articles 61 - 69 of 69
Full-Text Articles in Tax Law
Taxing Distributions Pursuant To Corporate Reorganizations, William M. Emery
Taxing Distributions Pursuant To Corporate Reorganizations, William M. Emery
Michigan Law Review
"Distributions" implies that we are concerned with the tax problems of the stockholder rather than those of the corporation. And while one corporation may be the stockholder of another, my emphasis will be primarily upon stockholders who are individuals, including, of course, trusts and estates who are taxed as individuals.
Taxation-Income Tax-Corporation Not Taxable On A Sale Of Property By Stockholders Following Genuine Liquidation Distribution, R. Lawrence Storms S.Ed.
Taxation-Income Tax-Corporation Not Taxable On A Sale Of Property By Stockholders Following Genuine Liquidation Distribution, R. Lawrence Storms S.Ed.
Michigan Law Review
The stockholders of a closely held electric utility corporation offered to sell all the corporate stock to a cooperative competitor. The cooperative countered with an offer to buy a part of the corporation's physical assets. Hoping to avoid a heavy corporate capital gains tax, the stockholders caused the corporation to distribute to them in partial liquidation the property in question, and then executed the previously contemplated sale themselves. The commissioner assessed and collected a capital gains tax from the corporation which then sued and recovered the amount of the tax in the court of claims. On appeal, held, affirmed. …
Attempts To Avoid Taxes On Corporate Distributions, W. Lewis Roberts
Attempts To Avoid Taxes On Corporate Distributions, W. Lewis Roberts
Kentucky Law Journal
No abstract provided.
Family Partnerships Under The Income Tax, Yale A. Barkan
Family Partnerships Under The Income Tax, Yale A. Barkan
Michigan Law Review
The usual type of family partnership has the taxpayer operating or organizing a business, and giving or selling a portion of that business to his wife or children. The aim of the taxpayer is to divide his income among members of the family group. The profits are thus taxed to two or more individuals, rather than to the taxpayer alone. Recognition of these family partnerships for federal income tax purposes is just one aspect of the family income problem.
Federal Estate And Gift Taxation: A Review, Paul G. Kauper
Federal Estate And Gift Taxation: A Review, Paul G. Kauper
Michigan Law Review
Today's tax-encumbered citizen is not only aware that death and taxes are certain but also realizes that they walk hand-in-hand. At the most he may experience a sense of nostalgic grief over Pliny the Younger's argument that an inheritance tax "is an 'unnatural' tax, since it augments the grief and sorrow of the bereaved." He knows that as a matter of history Pliny's argument, however touching and delicate, has not deterred ways and means committees, intent on meeting revenue needs.
Taxation - Income Tax - Liability Of Settlors Of Irrevocable Short Term Trusts, Robert M. Warren
Taxation - Income Tax - Liability Of Settlors Of Irrevocable Short Term Trusts, Robert M. Warren
Michigan Law Review
In a recent significant decision the Supreme Court of the United States has declared that, under certain circumstances, income from irrevocable short-term trusts may be taxed to the settlor. This conclusion is contrary to the previously accepted notion that there was no authority for such a tax under existing provisions of the Revenue Act. In the light of this and other recent decisions the matter of taxation of income from short-term trusts assumes renewed significance.
Taxation - Social Security - Dissolution Of Corporation And Formation Of Partnership As Means Of Avoiding Tax, Arthur P. Boynton
Taxation - Social Security - Dissolution Of Corporation And Formation Of Partnership As Means Of Avoiding Tax, Arthur P. Boynton
Michigan Law Review
The O Company surrendered its corporate charter and began operating under an agreement purporting to establish a partnership relation between the former officers and employees whereby complete management including the power to employ, discharge and control the duties of its members was vested in a "board of control" elected by and subject to changes made by the majority in interest. Net profits and losses were shared in proportion to the respective interests. The firm could be dissolved only by a vote of the majority in interest and not by transfer of interest, death or resignation of a member. Advice was …
Federal Gross Estate Tax-Constitutionality-Revocable Transfers By Way Of Trust
Federal Gross Estate Tax-Constitutionality-Revocable Transfers By Way Of Trust
Michigan Law Review
Five recent decisions of the United States Supreme Court, together with a decision of the United States Court of Appeals for the Third Circuit, have considerably changed some of the currently accepted theories regarding the taxability under the Federal Estate Tax of transfers reserving various degrees of control to donors, both with respect to what may be considered to be a sufficient reserved control and what the constitutional limits on the taxing power may be. Some perplexing questions have been settled by these decisions while others quite as vexing seem to have been raised and left for future determination.
The Reduction Of Income Taxes Through The Use Of Trusts, William C. Warren
The Reduction Of Income Taxes Through The Use Of Trusts, William C. Warren
Michigan Law Review
Obviously the draftsmen of the first Revenue Act under the Sixteenth Amendment could not foresee every possibility of tax avoidance and adequately prevent such avoidance by express statutory provisions. Since the enactment of the Revenue Act of 1913, Congress has made constant efforts in each succeeding Revenue Act to close the loopholes discovered by tax lawyers. The success of these efforts has been most remarkable, particularly in comparison with the similar efforts of England under her income tax laws. Indeed, it may fairly be said that the enactment. of the Gift Tax Act in 1932 wrote the final chapter of …