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Potential corporate tax abuse should be eliminated

Article Abstract:

IRC section 351 should be amended to eliminate the ability of corporations to abuse the mandatory deferral provision by using it to create artificial losses for stock transferees. Section 351's gain and loss deferral legitimately applies to exchanges of stock for property at the corporate formation stage. However, the loss deferral serves little purpose and allows for contributions of loss property for the purpose of creating double losses. Congress should amend the section to eliminate loss deferral. If Congress does not act, the business purpose doctrine and continuity of ownership rules could be used by the IRS to attack abusive transactions.

Public Finance Activities, Tax Management, Corporate Income Taxes, Standards, Tax accounting, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation)

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Corporate tax shelters

Article Abstract:

A panel discussion regarding corporate tax shelters, conducted as part of the 52cd annual Federal Tax Conference, is presented.

Beliefs, opinions and attitudes, Panel Discussion, Coustan, Harvey L., McCormally, Timothy J., Mikrut, Joseph, Trier, Dana L.

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Beyond the smell test: the role of substantive anti-avoidance rules in addressing the corporate tax shelter problem

Article Abstract:

The author discusses the application of substantive anti-avoidance rules to corporate tax shelters.

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