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Articles 541 - 560 of 560
Full-Text Articles in Taxation-Federal
Federal Taxation - Tax Aspects Of Corporate Buy And Sell Agreement, Joel D. Tauber S.Ed.
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.
Tax Considerations In Organizing A Corporation, Marvin D. Kelner
Tax Considerations In Organizing A Corporation, Marvin D. Kelner
Cleveland State Law Review
It is almost impossible, and certainly impractical, to prepare a definitive checklist of incorporation procedures, which will guarantee complete safeguard for all of the "watchdog sections" of the present Internal Revenue Code and further guarantee the lowest tax burden for the corporation and its stockholders. The most that any careful lawyer can do is to apply known and foreseeable procedures, which have been tried and tested in the courts, to any particular company he is engaged in incorporating.
Taxation - Federal Income Tax - Corporate Accumulations, Stock Dividends And The "Preferred Stock Bail-Out," And Taxability Of The Corporation Upon The Distribution Of "Inventory Assets" Under The Internal Revenue Code Of 1954, Alice Austin S.Ed.
Michigan Law Review
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distributions, some of the major interpretative problems existing under the 1939 code which Congress has failed to resolve, as well as some of the major interpretative difficulties which arise for the first time under the 1954 code.
Tax Advantages Of Foundations And Exempt Organizations, Joseph Berman, Daniel S. Berman
Tax Advantages Of Foundations And Exempt Organizations, Joseph Berman, Daniel S. Berman
Cleveland State Law Review
Businessmen these days are playing an ever increasing role in the creation and support of "non-profit" philanthropic foundations. Their purpose is a dual one; to save taxes and to immortalize a family name, and they are as old as the pyramids. We know of about 20,000 foundations existing in England, but the large broad-purpose foundations were created in the United States. The greatest expansion in this area is attributable to the family and corporate foundations. The corporation tax of 52% and the individual income tax of up to 91% are so severe that high-bracket taxpayers can give to charity at …
Taxation - Federal Income Tax - Exchange Of Debentures For Preferred Stock As Tax-Free Reorganization, Raymond R. Trombadore S.Ed.
Taxation - Federal Income Tax - Exchange Of Debentures For Preferred Stock As Tax-Free Reorganization, Raymond R. Trombadore S.Ed.
Michigan Law Review
Plaintiff held common and preferred stock of the Gulf States Paper Corporation. In 1942 plaintiff received new debentures in exchange for his preferred stock, pursuant to a plan for the recapitalization of the company whereby the entire 25,000 shares of previously outstanding preferred stock (including plaintiff's 208 shares) were exchanged for new debentures of like value. In 1950 the Commissioner assessed an income tax deficiency against plaintiff, determining that the redemption and cancellation of the preferred stock represented a distribution essentially equivalent to the distribution of a dividend and taxable under section 115(g)(1) of the Internal Revenue Code. Plaintiff sued …
Personal Holding Companies And Gross Income, Harvey Mahlig
Personal Holding Companies And Gross Income, Harvey Mahlig
Cleveland State Law Review
There are many small corporations, the ownership o fwhich is in the hands of a family group or a few individuals, which are susceptible to personal holding company rules. These require a careful analysis of stock ownership and gross income. While it may not have been the intention of an individual or of a group to form a personal holding company, circumstances may arise during a year which would qualify the corporation as one. A change in stock ownership, a change in the type of gross income or a change in the amount of gross income could very well transform …
The Western Hemisphere Trading Corporation; In Outline, Samuel Laderman
The Western Hemisphere Trading Corporation; In Outline, Samuel Laderman
Cleveland State Law Review
One of the last frontiers of effective tax reduction exists in the exporting field. This device was specifically created by Congress to enable American corporations trading in foreign countries within the Western Hemisphere to compete with foreign corporations and has been approved by the Commissioner of Internal Revenue. There is no federal law providing for the incorporation of Western Hemisphere Trade Corporations. The corporations are organized under applicable state law and qualify as Western Hemisphere Trade Corporations.
Discharge Of Corporate Indebtedness At Less Than Face Value Under The Internal Revenue Code, Harvey Mahlig
Discharge Of Corporate Indebtedness At Less Than Face Value Under The Internal Revenue Code, Harvey Mahlig
Cleveland State Law Review
Prior to 1939 whenever a corporation paid less than the face amount of an obligation in full satisfaction thereof, taxable income was realized to the extent of the difference. In 1939 paragraph (9) was added to Section 22 (b) of the InternalRevenue Code. Therein it was provided that there should not be included in the taxable income of a corporation the amount of income attributable to the discharge of any indebtedness as evidenced by a security, provided at the time of such discharge the corporation was in an unsound financial condition. In orderto obtain the relief provided, the corporation had …
Taxation; Deductibility Of Corporate Contributions To A Group Annuity Policy And An Employee's Trust, Daniel R. Mccarthy
Taxation; Deductibility Of Corporate Contributions To A Group Annuity Policy And An Employee's Trust, Daniel R. Mccarthy
Cleveland State Law Review
Discussion of Lincoln Electric Company v. Commissioner of Internal Revenue, 17 Tax Court 1600 (1952): The petitioner, a manufacturing company, paid the sum of $575,206.43 into a retirement annuity policy for its employees and contributed the sum of $1,000,000.00 to an employees' trust. Held: Such payments constituted ordinary and necessary business expenses and were deductible under section 23 (a) (1)(A) of the Internal Revenue Code.
Book Reviews, W. Barton Leach, Joe Tussman, Charles O. Gregory, Charles Fahy, John C. O'Byrne Jr., Joseph Curtis, Charles Fairman, Ralph R. Neuhoff, Joseph Hawley Murphy, Charles L. Black Jr., Roscoe L. Barrow, John Hanna
Book Reviews, W. Barton Leach, Joe Tussman, Charles O. Gregory, Charles Fahy, John C. O'Byrne Jr., Joseph Curtis, Charles Fairman, Ralph R. Neuhoff, Joseph Hawley Murphy, Charles L. Black Jr., Roscoe L. Barrow, John Hanna
Journal of Legal Education
No abstract provided.
Taxation--Income Tax--Family Partnerships--Application Of The Tower-Lusthaus Doctrine, Earl R. Boonstra S.Ed.
Taxation--Income Tax--Family Partnerships--Application Of The Tower-Lusthaus Doctrine, Earl R. Boonstra S.Ed.
Michigan Law Review
Respondent and his four sons formed a partnership in 1939. The sons contributed cattle and property purchased from respondent who accepted their notes in return. Subsequently, part of the notes were forgiven and part paid from shares of the firm proceeds. A firm bank account was opened on which all members could draw. It was planned that all the sons would render substantial services to the partnership. However, the plan was disrupted when the two eldest were called to military duty, and the two minor sons continued their education. A partnership return was filed for 1940. The Commissioner determined a …
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.
Taxation - Federal Income Tax - Capital Gain On Sale Of Partnership Interest, Herbert Sott
Taxation - Federal Income Tax - Capital Gain On Sale Of Partnership Interest, Herbert Sott
Michigan Law Review
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subsequent to his entering the partnership in 1932. The government contended that the taxpayer acquired and disposed of an interest in specific partnership assets and that the period for determining the capital gains percentages was properly measured from the date of acquisition of the specific capital assets. In his suit for refund on part of the tax thus computed, the taxpayer claimed that the partnership was a separate juristic entity, that his interest therein was an intangible capital asset, and that the period …
Federal Income Tax In Relation To Consumer Cooperatives, Joseph O'Meara
Federal Income Tax In Relation To Consumer Cooperatives, Joseph O'Meara
Journal Articles
The taxation of consumer cooperative associations has proceeded on an erroneous assumption deriving from Eisner v. Macomber. Contrary to that assumption, so long as these non-profit, mutual-benefit undertakings confine themselves to their proper functions they have no income under the Sixteenth Amendment and cannot validly be required to pay an income tax.
Taxation - Federal Income Tax - Deductions - Loss Upon Sale To Corporation Wholly Owned By Taxpayer, G. Randall Price
Taxation - Federal Income Tax - Deductions - Loss Upon Sale To Corporation Wholly Owned By Taxpayer, G. Randall Price
Michigan Law Review
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares of stock in partial payment of a debt which he owed to X corporation. The selling price, which was the market value of the stock, was less than the stock had cost the taxpayer. It was found that the sale was entered into with the intent of creating a deductible loss and thus reducing the taxpayer's taxable income. In computing his taxable income for 1932, the taxpayer deducted the amount of the loss on the sale of this particular stock to his wholly …
Recent Important Decisions, Michigan Law Review
Recent Important Decisions, Michigan Law Review
Michigan Law Review
Carriers of Passengers - Duty to Stop at Station to Permit Passenger to Alight-Contributory Negligence of Passenger Plaintiff's intestate was riding in the front end of a crowded vestibule car in the coach next to the tender of the eengine. When the train stopped at his station he tried to leave by the front end, but found the door from the vestibule closed. As he did not know how to open it, or was unwilling to be carried by his station, he stepped from his platform to the bumper of the tender and tried to follow it to the side …
Domestic Corporate Tangible And Intangible Invested Capital, Frederick M. Thulin
Domestic Corporate Tangible And Intangible Invested Capital, Frederick M. Thulin
Michigan Law Review
With a tax law on the statute books that fixes a moderate flat rate of taxation on business income, no question of invested capital need be considered. The income tax laws of 1913 and 1916 and the flat rate or normal tax section of the 1917 law and the proposed 1918 law bear out this statement.
Corporate Earnings As Gains Profits And Income As Depending Upon The Time Of Their Accrual, Robert M. Drysdale, Maurice C. Mcgiffin
Corporate Earnings As Gains Profits And Income As Depending Upon The Time Of Their Accrual, Robert M. Drysdale, Maurice C. Mcgiffin
Michigan Law Review
The discussion here has to do with the earnings of corporations as taxable income, whether such earnings remain in the hands of the corporation accumulating them, or are distributed to the stockholders as dividends, the inquiry being limited, however, to the question of the time of their accrual as affecting their taxability.
The Corporation Tax Decision, Ralph W. Aigler
The Corporation Tax Decision, Ralph W. Aigler
Articles
Seldom, if ever, in the history of the country has the Supreme Court been called upon within a comparatively short period of time to decide so many questions of widespread interest and vital importance as has been the case during the last year or two. Attempts on the part of the state and national governments to regulate and control corporations, which in recent years have come to exercise such a large and not always wholesome influence upon affairs generally, have been the occasion for the consideration by the court of many of the important cases recently presented. Among these are …
The Constitutionality Of The Federal Corporation Tax, Ralph W. Aigler
The Constitutionality Of The Federal Corporation Tax, Ralph W. Aigler
Articles
During the special session of Congress held the past summer there was enacted as an amendment to the new Tariff Law what is generally known as the Federal Corporation Tax.1 At the time of its consideration in Congress and since its enactment there has been considerable discussion regarding the constitutionality of the measure, and no little doubt has been expressed as to its validity.