New Morris Trust provisions have broad reach

Article Abstract:

The Taxpayer Relief Act of 1997 includes new provisions aimed at eliminating the tax benefit afforded corporations which characterize sale of asset transactions as tax-free Morris Trust transactions. Gain must be recognized by corporations distributing assets in such look-alike transactions in the same amount that they would recognize if they sold controlled corporations' stock for fair market value. Recognition can be avoided if the presumption that the acquisition and spin-off occurring in a specified four-year period are not related is rebutted.

Laws, regulations and rules, Trusts and trustees, Trustees, Trusts (Law), Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation)

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State tax trends - CCH State Tax Advisory Board discussion

Article Abstract:

A panel convening at an April 1998 meeting of the CCH State Tax Advisory Board discussed state taxation issues centering around two federal cases, and on Delaware holding companies, nexus, and common carrier issues. Federal and state law conflicts were considered when the panel discussed the US Supreme Court cases of Lunding and Newsweek.

United States, Tax Law, Public Finance Activities, States, Evaluation, Influence, Panel Discussion, State taxation, Domicile, Domicile (Residence)

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