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The transformation of entity classification

Article Abstract:

The revisions to the classification tests for partnerships, corporations and other entities that have been proposed by the IRS in Notice 95-14 may result in the simplification that many taxpayers seek, but the partnership anti-abuse regulations will ensure that the IRS is not ceding any control to taxpayers. The entity classification tests have come into question with the rise of limited liability companies. Under the anti-abuse regulations, tax practitioners have been seeking advance approval for tax planning schemes.

Author: Luscombe, Mark A.
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
Limited liability

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The emerging hybrid structure that can best meet the goals of participants in an e-commerce start-up

Article Abstract:

The author discusses the use of a hybrid, partnership-corporation, structure by high tech start-up companies as a means of avoiding tax problems encountered by using a limited liability company structure.

Author: Penick, Barksdale
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2001
High technology industry, Hybrid instruments (Finance), Hybrid instruments (Securities)

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Opening Pandora's box: who is (or should be) a partner?

Article Abstract:

The authors discuss partnership classification, how partnership classification law applies to economic relationships, and how these principles apply to developing corporate structures.

Author: Sloan, Eric B., Kraft, Christine
Publisher: CCH, Inc.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2001

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Subjects list: United States, Taxation, Corporate taxes, Partnership, Partnerships, Corporations
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