Taxes: The Tax Magazine 1995 |
Title | Subject | Authors |
Advance pricing agreements: policy and practice. | Business | Geralyn M. Fallon |
Application of new intercompany transaction regulations to selected transactions.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Jerred G. Blanchard Jr. |
A proposal for achieving substantial economic effect. (partnership allocations) | Business | John J. O'Neill |
Assessing the long-awaited LLC classification guidelines. (limited liability company) | Business | Kenneth L. Harris, Francis J. Wirtz |
Attributional nexus: waiting for the levee to break. | Business | William R. Thomas |
A zero income tax rate for U.S. exporters. | Business | William W. Bell |
Back to the Code: a reexamination of the continuity doctrines and other current issues in reorganizations.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | James M. Lynch |
Casualty gains - an oxymoron, or just a trap for unwary taxpayers? | Business | Steven C. Thompson, Nell Adkins |
Clear reflection of income: using financial product principles in other areas of tax law.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Thomas L. Evans |
Comparison of H.R. 1215's "American Dream Savings" account to current IRA provisions. (individual retirement accounts) | Business | Michael J.R. Hoffman |
Contingent payment debt instruments - a light at the end of the tunnel. | Business | Kirk Van Brunt |
Convertible debt: conversion as a bargain purchase.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Christian E. Kimball |
Corporate combining transactions.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Eric Solomon |
Corporate integration. | Business | Elvira Breslin |
Does a late return shorten the time for claiming a refund? | Business | Ronald A. Stein |
Downstream mergers and inversion transactions.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Laurence J. Stein |
Early resolution of federal tax controversies.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Robert H. Aland, James L. Malone III, Robert J. Neurauter, Joel V. Williamson |
Estate planning advantages of LLCs over S corporations. (limited liability companies) | Business | Peter J. Melcher |
Get ready for the 1994 tax season. | Business | John J. Mueller |
Getting out the vote: the use of voting rights in tax planning.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Todd F. Maynes |
High court extends standing to sue to third parties. (tax refund suit) | Business | George P. Cuonzo |
International R&D and technology transfer arrangements.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Paul W. Oosterhuis |
IRS hopes to get employee tip reporting on "TRAC." (Tip Reporting Alternative Commitment) | Business | Ray Suelzer |
IRS on minority interest discounts:it don't mean a thing if it still got that swing. | Business | Steven A. Horowitz, Alfred S. Scope |
Itemized deduction and exemption limits. | Business | Mildred Carter |
Lowering your estimated tax payments. | Business | John J. Mueller |
Neutral cost recovery system boosts depreciation benefits. | Business | Ray Suelzer |
New GATT agreement may cause the recognition of gain on partnership distributions of marketable securities. (General Agreement on Tariffs and Trade) | Business | Allan Karnes, Raymond F. Wacker |
On an IRS mega-plan for costly and unnecessary random audits. | Business | Amir D. Aczel |
Passive foreign investment companies. | Business | Gregory Slamowitz |
Planning for an unlimited revaluation period on prior gifts. | Business | Janet A. Meade |
Planning to minimize exposure to the "100 percent penalty." (responsibility for withheld taxes) | Business | Mark L. Lubin |
Proposed regulations address relief for real estate professionals under the passive loss rules. | Business | Richard M. Lipton |
Proposed regulations threaten tax-exempt bond financing of public infrastructure improvements that benefit business properties. | Business | Griffith F. Pitcher |
Questions about the deduction of environmental cleanup costs after Revenue Ruling 94-38. | Business | Charles E. Price, Leonard G. Weld |
Reasonable compensation in recent Tax Court cases. | Business | Dale L. Davidson |
Recent developments in the taxation of punitive damage awards. | Business | Kevin A. Palmer |
Redemptions and owner succession in the family business. | Business | James R. Hamill |
Related corporations and triangular dividends: can the circle be squared? | Business | James A. Fellows, Michael A. Yuhas |
Restrictive proposed regulations on publicly traded partnerships could cause any partnership to be taxed as a corporation. | Business | Richard M. Lipton, Sanford C. Presant, Leslie H. Loffman |
S corporations and their shareholders: the issue of constructive distributions. | Business | James A. Fellows, Michael A. Yuhas |
Section 2701 valuation issues in a transfer of family business interests. | Business | Hamid K. Kordestani |
Spink v. Lockheed Corporation: the Ninth Circuit outlaws pension plan window waivers. | Business | Matthew J. Renaud |
"Square peg, meet round hole": classifying LLC members as "general partners" or "limited partners" for federal tax purposes. (limited liability companies) | Business | Steven G. Frost |
Stock redemption costs: an analysis of conflicting judicial interpretations. | Business | Leonard G. Weld, Arlette Wilson |
Taxing retirement distributions at divorce in the absence of a qualified domestic relations order. | Business | John C. Zimmerman |
The dilemma of deficient deficiencynotices. | Business | Leandra Lederman Gassenheimer |
The final partnership anti-abuse regulation: the Treasury redefines the "intent of Subchapter K." | Business | Herman J. Marino |
The limits of literalism: the effect of substance over form, clear reflection and business purpose considerations on the proper interpretation of Subchapter K.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | William F. Nelson |
The New York Limited Liability Company Law: classification and conversion issues. | Business | Damian M. Hovancik |
The option attribution rules of the Internal Revenue Code. | Business | Gary B. Mandel |
The potential traps for the unwary in a short-against-the-box transaction. | Business | David R. Nave |
The section 704(c)(1)(B) proposed regulations. | Business | Terence Floyd Cuff |
The separate line of business regulations revisited. | Business | Richard S. Leaman |
The tax treatment of royalty income from affinity card programs. | Business | Kenton D. Swift |
The unending lure of Puerto Rico's unique tax regime for the U.S. entrepreneur. | Business | Stephen A. Mihaly |
Time for individuals to review withholding. | Business | Marie O'Donnell |
Top ten reasons for professionals to consider using LLCs. (limited liability companies) | Business | Sheldon I. Banoff |
Transportation expense deduction limited for home-officed taxpayers. | Business | William V. Vetter |
Use, abuse, and anti-abuse: policy considerations affecting the nature of regulatory guidance.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Kenneth W. Gideon |
Use of holding companies in international tax planning.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | D. Kevin Dolan, Michael F. Walsh |
Use spending accounts to save on dependent expenses. | Business | Lawrence A. Perlman |
Using partnerships in international tax planning.(48th Annual Federal Tax Conference of the University of Chicago Law School) | Business | Gregg D. Lemein, David A. Waimon, Barbara C. Spudis |
When is an innocent spouse really innocent? | Business | Gary L. Maydew |
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