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Articles 481 - 510 of 560
Full-Text Articles in Taxation-Federal
The Art Of Regulation Drafting: Structured Discretionary Justice Under Section 355, John W. Lee
The Art Of Regulation Drafting: Structured Discretionary Justice Under Section 355, John W. Lee
Faculty Publications
This article analyzes the 35-year evolution of the section 355 regulations from the perspectives of the jurisprudential dichotomy between general principles and detailed rules and administrative law theory as to agency discretion.
Ird And S Corporations, Gregory V. Gadarian, Jonathan G. Blattmachr
Ird And S Corporations, Gregory V. Gadarian, Jonathan G. Blattmachr
Touro Law Review
No abstract provided.
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Articles
The General Utilities doctrine is the name given to the now largely defunct tax rule that a corporation does not recognize a gain or a loss on making a liquidating or nonliquidating distribution of an appreciated or depreciated asset to its shareholders. The roots of the doctrine, can be traced to a regulation promulgated in 1919 that denied realization of gain or loss to a corporation when making a liquidating distribution of an asset in kind. No regulatory provision existed which specified the extent to which realization would or would not be triggered by a nonliquidating distribution such as a …
The Character Of A Partner's Distributive Share Under The "Substantial Economic Effect" Regulation, Alan Gunn
The Character Of A Partner's Distributive Share Under The "Substantial Economic Effect" Regulation, Alan Gunn
Journal Articles
Partnership income and deductions are allocated according to the amount and the character of each partner's distributive share. This article examines the ways in which the section 704(b) regulations apply the "substantial economic effect" test to character allocations. It argues that it is important to distinguish allocations of character from allocations of amounts to understand these regulations. This is because tests that the regulations apply to character issues have to do with source-measurement correspondence and proration, while amounts are determined according to economic effect in the capital account sense. Although the regulations' rules for character allocations purport to define "substantiality," …
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Faculty Publications
No abstract provided.
Section 83 Applied To Partnership Transactions: The Road To Certainty In Planning And Controlling The Tax Consequences Of Exchanges Of Partnership Interests For Services, Charles R. Gehrke
Section 83 Applied To Partnership Transactions: The Road To Certainty In Planning And Controlling The Tax Consequences Of Exchanges Of Partnership Interests For Services, Charles R. Gehrke
Florida State University Law Review
No abstract provided.
Recent Developments In The Federal Tax Law Treatment Of Nominee Corporations, Carla Green
Recent Developments In The Federal Tax Law Treatment Of Nominee Corporations, Carla Green
Florida State University Law Review
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.
Serving Two Masters: Commercial Hues And Tax Exempt Organizations, Lawrence Zelenak
Serving Two Masters: Commercial Hues And Tax Exempt Organizations, Lawrence Zelenak
Seattle University Law Review
This article will describe the statutory and regulatory framework of section 501(c)(3), examine how the test has been applied, criticize the test, and suggest a test more in keeping with the language and the spirit of section 501(c)(3). The proposed test is this: If the questioned activity directly accomplishes an exempt purpose of the organization, and if all profits from the activity are used in a manner consistent with the organization's exempt purposes, 6 then the organization should be granted exempt status, whether or not the organization's activities are imbued with a "commercial hue."
Allison V. United States, 83-1 U.S. Tax Cas. (Cch) ¶ 9241 (Ct. App. Fed. Cir. 1983), Peter Doragh
Allison V. United States, 83-1 U.S. Tax Cas. (Cch) ¶ 9241 (Ct. App. Fed. Cir. 1983), Peter Doragh
Florida State University Law Review
Partnership Taxation-INTANGIBLE DRILLING COSTS MEET SUBSTANTIAL ECONOMIC EFFECT
Partnership Allocations: Flipping Through The Substantial Economic Effect Hoops, Frank Rainer
Partnership Allocations: Flipping Through The Substantial Economic Effect Hoops, Frank Rainer
Florida State University Law Review
No abstract provided.
The Existence Of State And Tax Partnerships: A Primer, Donald J. Weidner
The Existence Of State And Tax Partnerships: A Primer, Donald J. Weidner
Scholarly Publications
No abstract provided.
The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven
The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven
Faculty Publications
No abstract provided.
Clarifying The Characteristics Of Brother-Sister Controlled Groups Of Corporations: United States V. Vogel Fertilizer Co.
Washington and Lee Law Review
No abstract provided.
Ogiony V. Commissioner, 617 F.2d 14 (2d Cir. 1980), Vincent A. Sable
Ogiony V. Commissioner, 617 F.2d 14 (2d Cir. 1980), Vincent A. Sable
Florida State University Law Review
Taxation-DISREGARDING THE CORPORATE ENTITY-PARTNERS UNABLE TO IGNORE EXISTENCE OF CORPORATION USED FOR FINANCING PURPOSES
Corporate Distributions And The Income Tax: A Consideration Of The Inconsistency Between Subchapter C And Its Underlying Policy, Charles O'Kelley
Corporate Distributions And The Income Tax: A Consideration Of The Inconsistency Between Subchapter C And Its Underlying Policy, Charles O'Kelley
Faculty Articles
The issue of whether the sale of shares to an issuer shall be treated as a dividend or as received in exchange for a capital asset has troubled Congress, courts, and commentators since the Revenue Act of 1913. If a corporation redeems some of its shares or distributes all of its assets in complete liquidation, the transaction is generally described as having the characteristics of a divided to the extent the distribution is ‘out of earnings and profits' and the characteristics of a sale to the extent that it terminates the equity interest of the redeemed party. In light of …
The Double Jeopardy Of Corporate Profits, Constantine N. Katsoris
The Double Jeopardy Of Corporate Profits, Constantine N. Katsoris
Buffalo Law Review
No abstract provided.
Double Jeopardy Of Corporate Profits, The , Constantine N. Katsoris
Double Jeopardy Of Corporate Profits, The , Constantine N. Katsoris
Faculty Scholarship
The more one reads about our economy, the more one is baffled and alarmed. Permanent solutions to economic problems are elusive. Treating one financial malaise often aggravates another sector of the economy, necessitating a delicate balancing of conflicting interests. Furthermore, the problems are complicated by the constant influence of foreign forces. Nevertheless, most economists agree that any solution will require enormous funding. Unfortunately, the public has little, if any, confidence in our tax system. Indeed, some tax laws and proposals have been referred to as "obscene" and a "disgrace to the human race." Few quarrel with the aptness of such …
Reflections On Section 382: Searching For A Rationale, J. Clifton Fleming Jr.
Reflections On Section 382: Searching For A Rationale, J. Clifton Fleming Jr.
BYU Law Review
No abstract provided.
Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles
Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles
Vanderbilt Law Review
This Note first will set forth the Treasury Department's perception of the present abuses of tax shelter partnerships and will analyze existing procedural rules, the Treasury Department's proposed amendments, and the House of Representatives' proposed amendments in light of these abuses. Next, the Note will examine the substantive law of Subchapter K and will attempt to point out the probable effects of the proposed amendments on the aggregate concept of partnerships, on substantive partnership tax law, and on the viability of the partnership form of business. Finally, this Note will propose a solution to the problem of tax shelter partnership …
Federal Taxation-Reorganizations-Distribution Of Boot To Shareholders Of Merged Corporation Taxable As Dividend, Not Capital Gain-Shim Berg V. United States
BYU Law Review
No abstract provided.
Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran
Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran
UIC Law Review
No abstract provided.
Recent Interpretations Of The "Meaningful Reduction" Test Of I.R.C. Section 302(B)(L), Boyd C. Randall
Recent Interpretations Of The "Meaningful Reduction" Test Of I.R.C. Section 302(B)(L), Boyd C. Randall
BYU Law Review
No abstract provided.
Distributions In Kind And The Dividends Paid Deduction-Conflict In The Circuits, Dwight Drake
Distributions In Kind And The Dividends Paid Deduction-Conflict In The Circuits, Dwight Drake
BYU Law Review
No abstract provided.
Incorporating A Cash Basis Business: The Problem Of Section 357©
Incorporating A Cash Basis Business: The Problem Of Section 357©
Washington and Lee Law Review
No abstract provided.
Eliminating The Capital Gains Preference. Part Ii: The Problem Of Corporate Taxation, Michael J. Waggoner
Eliminating The Capital Gains Preference. Part Ii: The Problem Of Corporate Taxation, Michael J. Waggoner
Publications
No abstract provided.
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
Faculty Publications
No abstract provided.
Eliminating The Capital Gains Preference. Part I: The Problems Of Inflation, Bunching And Lock-In, Michael J. Waggoner
Eliminating The Capital Gains Preference. Part I: The Problems Of Inflation, Bunching And Lock-In, Michael J. Waggoner
Publications
No abstract provided.
A Definition Of "Liabilities" In Code Sections 357 And 358(D), Douglas A. Kahn, Dale A. Oesterle
A Definition Of "Liabilities" In Code Sections 357 And 358(D), Douglas A. Kahn, Dale A. Oesterle
Articles
Internal Revenue Code section 351(a) provides that no gain or loss shall be recognized if property is transferred to a corporation solely in exchange for its stock or securities and the transferors control the corporation immediately after the exchange. If, in addition to receiving stock or securities in an exchange that would otherwise qualify for section 351 treatment, a transferor receives other property or money -- "boot" -- any realized gain is recognized up to the amount of the money and the fair market value of the other property received. The transferee corporation's assumption of the transferor's liabilities or its …
Reorganization Of Savings And Loan Associations Under Section 368-A Return To The "Continuity Of Interest" Test
Washington and Lee Law Review
No abstract provided.