Abstracts

Law

Search abstracts:

Collaboration Between Tax-Exempt Research Organizations and Commercial Enterprises - Federal Income Tax Limitations

Article Abstract:

The study presents three reasons for the increasing success of collaboration between tax-exempt research organizations and corporations: (1) increased need of institutional funding, (2) increased recognition of business use of research, and (3) greater interest in rapid transition from research to business applications. Collaborations take various forms including research contracts, patent licensing and consultation. When corporations such as IBM and Exxon collaborate with nonprofit research laboratories, hospitals' and universities' issues such as academic freedom, patentability, trustee responsibility and federal government funding arise. The analysis focuses on forms of collaboration, scientific research requirements, exemption status, taxation of unrelated business income, and use of the Federal Tax Code with various collaboration agreements. Significant tax issues are identified. All research must qualify as scientific research performed in the public interest. Tax problems could occur if nonexempt corporations are controlled by exempt organizations, nonexempt enterprises are permitted to own more than an insignificant sum of the patents derived from the exempt organization's research, or the patents, copyright, or formulae are not presented to the public without discrimination. Tax-exempt status can easily be lost.

Research, Management, Tax planning, Tax exemption, Tax exemptions

---

Payments of Expenses by Credit Card: A Current Deduction For the Cash-Method Taxpayer

Article Abstract:

The credit card has made society in the United States virtually cashless. The Internal Revenue Service (IRS) has had to take a new look at how credit card purchases are handled as a deduction, especially to the cash-method taxpayer. The major question the IRS has to deal with is, when can a credit card transaction be considered a deduction to the cash-method taxpayer. In a tripartite credit card transaction in which a bank, a merchant and a consumer are involved, the bank pays the merchant at the time of the purchase and extends a line of credit to the consumer. Many tax analysts agree that since the merchant is paid off right away, this constitutes a sale and can be considered a deduction by the consumer. If, however, a consumer uses the purchase as an instant deduction, he is obliged to fulfill his obligation at a later date.

Credit cards

---

Gift-Leasebacks: The Taxpayer Continues to Win

Article Abstract:

The analysis of Circuit Court cases concerning gift- leaseback transactions concludes that they are good devices to decrease tax costs. There is usually a deduction to the grantor when he transfers commercial property to a trust and the trustee leases it back to him for use in his business. Proposals for structuring gift- leaseback situations are based upon a review of pro- Internal Revenue Service (IRS) cases and pro-taxpayer cases. Clifford Trust Requirements are explained. Most cases suggest that a grantor should not appoint himself as a trustee. Pertinent topics include: Rosenfield v. Commissioner, grantor control, the reasonable rent criterion, the bona fide business purpose criterion, and the disqualifying equity criterion.

Leases

Similar abstracts:

• Abstracts: Comments on New Proposed Regulations Under Section 897. Comments on Proposed Amendments to Section 367
• Abstracts: New Developments in Legislation, Regulations and Informal Agency Positions. part 3
• Abstracts: Model Selection 401(K) Plan. Technical corrections bill contains IRA provisions
• Abstracts: Controlling Computer Crime, Where Do We Stand? Computer Abuse: A Crime of the Times. ASIS Testifies on Capitol Hill
• Abstracts: The Other Industrial Security Programs. Sources for Professional Training in Security

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.