Stapled interests with a conduit

Article Abstract:

Business planning involving stapled or paired business interests has existed for many years, but the tax treatment of conduit entities utilizing stapled interests, such as real estate investment trusts (REITs), has changed. Income shifting for tax reduction purposes has been discouraged by IRC section 482. The enactment of section 269B was as a response to stapled interest planning using REITs, and section 7704 was a response to the use of master limited partnerships.

United States, Tax Management, Planning, Laws, regulations and rules, Tax accounting, Real estate investment trusts, Tax evasion, Interest (Law)

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Trends in state and local taxation: a roundtable discussion of the CCH State Tax Advisory Board

Article Abstract:

A group of state and local taxation experts discuss important tax issues. The issues addressed include taxation of electronic commerce. telecommunication industry taxes, nexus guidelines, telecommuting, limited liability companies, state administrative issues and corporate purchasing cards. US Supreme Court cases involving tax issues are also discussed.

Telecommunications services industry, Telecommunications industry, Beliefs, opinions and attitudes, Electronic commerce, E-commerce, Cronin, John J., Dean, J. Gary, Duncan, Harley T., Frankel, Paul H., Local taxation, Mines, Paull, Barry, George J., Castanias, Gregory A., Hayden, William, Koziski, Michael J., Morrone, Ann, Smith, Scott D., Wethekam, Marilyn

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Will limited liability companies lead to a single business tax?

Article Abstract:

The author discusses the possibility that states may enact a single business tax similar to the Michigan model to address revenue losses attributable to the increased use of limited liability companies. Studies done in California and Tennessee are discussed.

States, Limited liability companies

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