Taxes: The Tax Magazine 1995 - Abstracts

Taxes: The Tax Magazine 1995
TitleSubjectAuthors
Advance pricing agreements: policy and practice.BusinessGeralyn M. Fallon
Application of new intercompany transaction regulations to selected transactions.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessJerred G. Blanchard Jr.
A proposal for achieving substantial economic effect. (partnership allocations)BusinessJohn J. O'Neill
Assessing the long-awaited LLC classification guidelines. (limited liability company)BusinessKenneth L. Harris, Francis J. Wirtz
Attributional nexus: waiting for the levee to break.BusinessWilliam R. Thomas
A zero income tax rate for U.S. exporters.BusinessWilliam 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)BusinessJames M. Lynch
Casualty gains - an oxymoron, or just a trap for unwary taxpayers?BusinessSteven 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)BusinessThomas L. Evans
Comparison of H.R. 1215's "American Dream Savings" account to current IRA provisions. (individual retirement accounts)BusinessMichael J.R. Hoffman
Contingent payment debt instruments - a light at the end of the tunnel.BusinessKirk Van Brunt
Convertible debt: conversion as a bargain purchase.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessChristian E. Kimball
Corporate combining transactions.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessEric Solomon
Corporate integration.BusinessElvira Breslin
Does a late return shorten the time for claiming a refund?BusinessRonald A. Stein
Downstream mergers and inversion transactions.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessLaurence J. Stein
Early resolution of federal tax controversies.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessRobert H. Aland, James L. Malone III, Robert J. Neurauter, Joel V. Williamson
Estate planning advantages of LLCs over S corporations. (limited liability companies)BusinessPeter J. Melcher
Get ready for the 1994 tax season.BusinessJohn 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)BusinessTodd F. Maynes
High court extends standing to sue to third parties. (tax refund suit)BusinessGeorge P. Cuonzo
International R&D and technology transfer arrangements.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessPaul W. Oosterhuis
IRS hopes to get employee tip reporting on "TRAC." (Tip Reporting Alternative Commitment)BusinessRay Suelzer
IRS on minority interest discounts:it don't mean a thing if it still got that swing.BusinessSteven A. Horowitz, Alfred S. Scope
Itemized deduction and exemption limits.BusinessMildred Carter
Lowering your estimated tax payments.BusinessJohn J. Mueller
Neutral cost recovery system boosts depreciation benefits.BusinessRay Suelzer
New GATT agreement may cause the recognition of gain on partnership distributions of marketable securities. (General Agreement on Tariffs and Trade)BusinessAllan Karnes, Raymond F. Wacker
On an IRS mega-plan for costly and unnecessary random audits.BusinessAmir D. Aczel
Passive foreign investment companies.BusinessGregory Slamowitz
Planning for an unlimited revaluation period on prior gifts.BusinessJanet A. Meade
Planning to minimize exposure to the "100 percent penalty." (responsibility for withheld taxes)BusinessMark L. Lubin
Proposed regulations address relief for real estate professionals under the passive loss rules.BusinessRichard M. Lipton
Proposed regulations threaten tax-exempt bond financing of public infrastructure improvements that benefit business properties.BusinessGriffith F. Pitcher
Questions about the deduction of environmental cleanup costs after Revenue Ruling 94-38.BusinessCharles E. Price, Leonard G. Weld
Reasonable compensation in recent Tax Court cases.BusinessDale L. Davidson
Recent developments in the taxation of punitive damage awards.BusinessKevin A. Palmer
Redemptions and owner succession in the family business.BusinessJames R. Hamill
Related corporations and triangular dividends: can the circle be squared?BusinessJames A. Fellows, Michael A. Yuhas
Restrictive proposed regulations on publicly traded partnerships could cause any partnership to be taxed as a corporation.BusinessRichard M. Lipton, Sanford C. Presant, Leslie H. Loffman
S corporations and their shareholders: the issue of constructive distributions.BusinessJames A. Fellows, Michael A. Yuhas
Section 2701 valuation issues in a transfer of family business interests.BusinessHamid K. Kordestani
Spink v. Lockheed Corporation: the Ninth Circuit outlaws pension plan window waivers.BusinessMatthew J. Renaud
"Square peg, meet round hole": classifying LLC members as "general partners" or "limited partners" for federal tax purposes. (limited liability companies)BusinessSteven G. Frost
Stock redemption costs: an analysis of conflicting judicial interpretations.BusinessLeonard G. Weld, Arlette Wilson
Taxing retirement distributions at divorce in the absence of a qualified domestic relations order.BusinessJohn C. Zimmerman
The dilemma of deficient deficiencynotices.BusinessLeandra Lederman Gassenheimer
The final partnership anti-abuse regulation: the Treasury redefines the "intent of Subchapter K."BusinessHerman 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)BusinessWilliam F. Nelson
The New York Limited Liability Company Law: classification and conversion issues.BusinessDamian M. Hovancik
The option attribution rules of the Internal Revenue Code.BusinessGary B. Mandel
The potential traps for the unwary in a short-against-the-box transaction.BusinessDavid R. Nave
The section 704(c)(1)(B) proposed regulations.BusinessTerence Floyd Cuff
The separate line of business regulations revisited.BusinessRichard S. Leaman
The tax treatment of royalty income from affinity card programs.BusinessKenton D. Swift
The unending lure of Puerto Rico's unique tax regime for the U.S. entrepreneur.BusinessStephen A. Mihaly
Time for individuals to review withholding.BusinessMarie O'Donnell
Top ten reasons for professionals to consider using LLCs. (limited liability companies)BusinessSheldon I. Banoff
Transportation expense deduction limited for home-officed taxpayers.BusinessWilliam 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)BusinessKenneth W. Gideon
Use of holding companies in international tax planning.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessD. Kevin Dolan, Michael F. Walsh
Use spending accounts to save on dependent expenses.BusinessLawrence A. Perlman
Using partnerships in international tax planning.(48th Annual Federal Tax Conference of the University of Chicago Law School)BusinessGregg D. Lemein, David A. Waimon, Barbara C. Spudis
When is an innocent spouse really innocent?BusinessGary L. Maydew
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