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Articles 331 - 358 of 358

Full-Text Articles in Taxation-Federal Estate and Gift

Table Of Contents, Seattle University Law Review Sep 2019

Table Of Contents, Seattle University Law Review

Seattle University Law Review

No abstract provided.


Table Of Contents, Seattle University Law Review Feb 2019

Table Of Contents, Seattle University Law Review

Seattle University Law Review

No abstract provided.


Lack Of Marketability And Minority Discounts In Valuing Close Corporation Stock: Elusiveness And Judicial Synchrony In Pursuit Of Equitable Consensus, Stephen J. Leacock Jan 2016

Lack Of Marketability And Minority Discounts In Valuing Close Corporation Stock: Elusiveness And Judicial Synchrony In Pursuit Of Equitable Consensus, Stephen J. Leacock

Faculty Scholarship

No abstract provided.


The Family Llc: A New Approach To Insuring Dynastic Wealth, Evan Michael Purcell Sep 2015

The Family Llc: A New Approach To Insuring Dynastic Wealth, Evan Michael Purcell

The Journal of Business, Entrepreneurship & the Law

This Article introduces the taxpayer to the basic background principles needed to understand the inner workings of the investment, then provides a guide to drafting considerations for the family's attorney, and concludes with a general plan to maintain business legitimacy and take advantage of tax-favored status, while retaining the flexibility essential to combating the unexpected. Part II addresses the historically favored tax treatment of life insurance products, as well as relatively recent restrictive reforms. Part III addresses the background foundation of the LLC entity and surveys its skeletal structure. Part IV introduces a practical example of how to create an …


Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii Apr 2015

Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii

Georgia Journal of International & Comparative Law

No abstract provided.


Families For Tax Purposes: What About The Steps, Wendy G. Gerzog Jul 2009

Families For Tax Purposes: What About The Steps, Wendy G. Gerzog

All Faculty Scholarship

At least 4.4 million families in the U.S. are blended ones that include step-children and step-parents. For tax purposes, these steps receive preferential treatment for their status because they are on the one hand included as family members for many income tax benefit sections, but on the other hand excluded as family members for business entity attribution purposes and for gift and estate tax anti-abuse provisions. In the interests of fairness and uniformity, steps should be treated as family members for all tax purposes where steps have in fact voluntarily acted as their biological or adoptive counterparts, both when such …


Introducing The Law Of Nonprofit Organizations And Philanthropy, David A. Brennen Jan 2007

Introducing The Law Of Nonprofit Organizations And Philanthropy, David A. Brennen

Law Faculty Scholarly Articles

On January 5,2007, the Nonprofit and Philanthropy Law Section of AALS held its first program at the AALS Annual Meeting in Washington, D.C. The program, entitled "State-Level Legal Reform of the Law of Nonprofit Organizations," was a fitting way to launch what should prove to be a valuable contribution to the study of law relating to nonprofit organizations and philanthropy. This burgeoning area of academic legal study is well poised to grow by leaps and bounds in the coming years due to its impact on many traditional areas of legal study, including tax law, corporate law, estate law, trust law, …


A Complete Property Right Amendment, John H. Ryskamp Oct 2006

A Complete Property Right Amendment, John H. Ryskamp

ExpressO

The trend of the eminent domain reform and "Kelo plus" initiatives is toward a comprehensive Constitutional property right incorporating the elements of level of review, nature of government action, and extent of compensation. This article contains a draft amendment which reflects these concerns.


Breaking The Bank: Revisiting Central Bank Of Denver After Enron And Sarbanes-Oxley, Celia Taylor Sep 2005

Breaking The Bank: Revisiting Central Bank Of Denver After Enron And Sarbanes-Oxley, Celia Taylor

ExpressO

No abstract provided.


When The Endowment Tanks, Jeffrey J. Haas Jan 2003

When The Endowment Tanks, Jeffrey J. Haas

Articles & Chapters

No abstract provided.


Anatomy Of Valuing Stock In Closely Held Corporations: Pursuing The Phantom Of Objectivity Into The New Millennium, Stephen J. Leacock Jan 2001

Anatomy Of Valuing Stock In Closely Held Corporations: Pursuing The Phantom Of Objectivity Into The New Millennium, Stephen J. Leacock

Faculty Scholarship

No abstract provided.


Toward A Practical Estate-Tax Exclusion For Family-Run Businesses: Analysis Of Section 2033a And Proposal For Reform, Eric D. Chason, Robert T. Danforth Jan 1998

Toward A Practical Estate-Tax Exclusion For Family-Run Businesses: Analysis Of Section 2033a And Proposal For Reform, Eric D. Chason, Robert T. Danforth

Faculty Publications

In a previous work appearing in this Journal, the authors proposed an approach to estate and gift taxation that encourages productive behavior by the recipients of wealth. In this Article, the authors analyze, in the context of their earlier work, the new estate-tax exclusion for closely held businesses (section 2033A) created by the Taxpayer Relief Act of 1997. The authors describe the features of a practical family-run business exclusion and conclude that section 2033A, in its present form, fails as a practical exclusion. The authors catalogue those elements of section 2033A that should be retained and propose reforms of those …


The Proper Role Of The Estate And Gift Taxation Of Closely Held Businesses, Eric D. Chason, Robert T. Danforth Apr 1997

The Proper Role Of The Estate And Gift Taxation Of Closely Held Businesses, Eric D. Chason, Robert T. Danforth

Faculty Publications

The authors argue that the goals of estate and gift taxation are not served by taxing closely held businesses when the recipient of the business actively participates in its operation. Further, the authors suggest that taxing closely held businesses tends to harm capital production. The authors propose an approach to estate and gift taxation that encourages productive behavior by the recipients of wealth.


What's In A Name: An Argument For A Small Business Limited Liability Entity Statute (With Three Subsets Of Default Rules), Dale A. Oesterle, Wayne M. Gazur Jan 1997

What's In A Name: An Argument For A Small Business Limited Liability Entity Statute (With Three Subsets Of Default Rules), Dale A. Oesterle, Wayne M. Gazur

Publications

The recent proliferation of small business entity forms is primarily a result of their tax characterization. With the recent adoption of the IRS "check-the-box" regulations and, as a consequence, the elimination of traditional tax distinctions, many of these forms have lost their appeal. This article proposes starting over with one form, the "limited liability entity." Part I discusses the history of small business forms. Part II analyzes the current forms in light of the recent check-the- box legislation. Part III discusses the necessity of and rationale behind a unified entity statute. Finally, Part IV outlines a unified limited liability entity …


Pandora’S Box: Managerial Discretion And The Problem Of Corporate Philanthropy, Faith Stevelman Jan 1997

Pandora’S Box: Managerial Discretion And The Problem Of Corporate Philanthropy, Faith Stevelman

Articles & Chapters

Corporate giving to 501(c)(3) nonprofits (“charities”) is a more curious, varied and interesting phenomenon than commentators have recognized. Such “gifts” can be grouped generally into four categories. First, Giving to executives’ preferred charities represents an alternative form of compensation. Second, corporate philanthropy is often tied to the company’s commercial advertising, as a method of promoting consumer goodwill and sales. Thirdly, some corporate gifts may be motivated by their leaders’ desire to “give back” to the community, as an expression of corporate social responsibility. Finally, corporations may use contributions to politically enabled nonprofits, including think tanks and market-oriented/ “public interest” litigation …


The West Virginia Limited Liability Company Act: Time For A Change, Noel P. Brock Cpa Jan 1995

The West Virginia Limited Liability Company Act: Time For A Change, Noel P. Brock Cpa

West Virginia Law Review

No abstract provided.


Corporate Takeover Of Teaching Hospitals, Maxwell Gregg Bloche Jan 1992

Corporate Takeover Of Teaching Hospitals, Maxwell Gregg Bloche

Georgetown Law Faculty Publications and Other Works

This article explores the potential and the dangers of this novel form of collaboration between academic medicine and the for-profit world. The author focuses on those arrangements--purchases and leasing agreements--by which investor-owned corporations operate, for a profit, hospitals that serve as major medical teaching and research sites. He begins by reviewing how the evolving needs of academic medical centers and for-profit hospital chains have generated mutual interest in such arrangements. The author then considers some frequently expressed ethical, economic, and other public policy objections to the provision of hospital services by for-profit firms. Opponents of the acquisition and leasing of …


Ird And S Corporations, Gregory V. Gadarian, Jonathan G. Blattmachr Jan 1989

Ird And S Corporations, Gregory V. Gadarian, Jonathan G. Blattmachr

Touro Law Review

No abstract provided.


Tax Consequences For Corporate Divisions Of The Family Farm Corporation, Edwin T. Hood, John D. Shores, Charles S. Triplett Jan 1978

Tax Consequences For Corporate Divisions Of The Family Farm Corporation, Edwin T. Hood, John D. Shores, Charles S. Triplett

Faculty Works

No abstract provided.


Close Corporations In Estate Planning After The Tax Reform Act Of 1976, Edwin T. Hood Jan 1977

Close Corporations In Estate Planning After The Tax Reform Act Of 1976, Edwin T. Hood

Faculty Works

No abstract provided.


The Application Of Section 2036 To Inter Vivos Transfers Of Stock In Closely-Held Corporations, George A. Neidich Jan 1973

The Application Of Section 2036 To Inter Vivos Transfers Of Stock In Closely-Held Corporations, George A. Neidich

Buffalo Law Review

No abstract provided.


Recent Legislation Jan 1970

Recent Legislation

University of Richmond Law Review

This is a list of the recent legislation from 1970.


Initial Impressions Of The Treasury Report On Foundations, Marcus Schoenfeld Jan 1965

Initial Impressions Of The Treasury Report On Foundations, Marcus Schoenfeld

Cleveland State Law Review

Very recently in the United States Treasury Department submitted its study of private foundations to Congress. This is the most recent development in an attempt to delineate the proper role of foundations and their donors in our society, and more particularly their proper tax treatment. Although it is much too soon to predict the effect of the Treasury Report, since Congress itself asked for the study, it is quite likely that some more restrictive legislation will result.


Bosland: Estate Tax Valuation In The Sale Of Merger Of Small Firms, Herman L. Trautman May 1964

Bosland: Estate Tax Valuation In The Sale Of Merger Of Small Firms, Herman L. Trautman

Michigan Law Review

A Review of Estate Tax Valuation in the Sale of Merger of Small Firms. By Chelcie C. Bosland.


Abstracts Of Recent Cases, Boyd Lee Warner Ii Dec 1963

Abstracts Of Recent Cases, Boyd Lee Warner Ii

West Virginia Law Review

No abstract provided.


Setting The Price In An Close Corporation Buy-Sell Agreement, David Keith Page Mar 1959

Setting The Price In An Close Corporation Buy-Sell Agreement, David Keith Page

Michigan Law Review

The stockholders of a close corporation may consider it important to keep control of the business "within the family." This can be accomplished through a restrictive agreement, typically one which gives the corporation or the remaining stockholders a first option to purchase the shares of any departing stockholder. The original owners may also wish to guarantee themselves a ready purchaser for their stock when they die or leave the business. This second objective can be attained by adopting a restrictive agreement which places an obligation on the departing stockholder to sell to the corporation or to the surviving stockholders, who …


Federal Taxation - Tax Aspects Of Corporate Buy And Sell Agreement, Joel D. Tauber S.Ed. Feb 1959

Federal Taxation - Tax Aspects Of Corporate Buy And Sell Agreement, Joel D. Tauber S.Ed.

Michigan Law Review

It is the purpose of this comment to consider the tax problems connected with both types of "conventional" corporate buy and sell agreements. It should be recognized, however, that there are many questions of local law and business necessity that also exert influence on the use of such agreements.


The Second Circuit Reaffirms The Efficacy Of Restrictive Stock Agreements To Control Estate Tax Valuation, Edmund W. Pavenstedt Nov 1952

The Second Circuit Reaffirms The Efficacy Of Restrictive Stock Agreements To Control Estate Tax Valuation, Edmund W. Pavenstedt

Michigan Law Review

Owners of close corporations have for many years entered into agreements with each other requiring a stockholder who wishes to dispose of his holdings first to offer them to his fellow stockholders or to the corporation and, in the case of death, granting to the survivors or the corporation an option to buy the shares from the decedent's estate. Such agreements either fix a price per share or contain a formula or a provision for appraisal under which such price is to be determined. About twenty years ago two leading cases both decided by the United States Court of Appeals …