Business Entities 2004 |
Title | Subject | Authors |
704(c) gain in partnership mergers. | Business | Abrams, Howard E. |
American Jobs Creation Act includes provisions relevant to passthrough entities. | Business | |
Automatic relief where non-shareholder community property spouse fails to sign form 2553.(current developments)(rev. Proc. 2004-35, 2004-23 IRB 1029) | Business | Looney, Stephen R., Klein, I. Steven |
Basis increase denied to shareholder in related party loan restructuring. | Business | Looney, Stephen R., Klein, Steven I. |
Chief Judge Edward J. Damich: United States Court of Federal Claims. | Business | August, Jerald David |
Choice of business entity after JGTRRA.(Jobs and Growth Tax Relief Reconciliation Act of 2003) | Business | Jones, Darryl K., Kirk, David |
Choice of business entity after the 2003 tax act. | Business | Hall, Wells C. |
Choice of entity decision.(taxation) | Business | McNulty, Mary A. |
Current developments.(family limited partnerships) | Business | Looney, Stephen R., Klein, Steven I |
Current developments.(partnership, S corporation, disregarded entities laws) | Business | Harvey, Carol Kulish, Tod, Jim, Kwon, Michelle M. |
Effect of certain transactions on QSub and entity classification election status. | Business | |
FICA, FUTA and income tax withholding in connection with transfer of NQSOs and non-qualified deferred compensation incident to a divorce.(current developments)(Federal Insurance Contributions Act, Federal Unemployment Tax Act, non qualified stock option) | Business | Looney, Stephen R., Klein, I. Steven |
Final regs address mid-contract change in a taxplayer involved in a long-term contract.(current developments)(mid-contract rule TD 9137) | Business | Looney, Stephen R., Klein, I. Steven |
IC DISCs.(Interest Charge Domestic International Sales Corporation, exporting business entities) | Business | Loizeaux, James D. |
It ain't over 'til it's over.(report on Harbor Cove Marina Partnership case) | Business | Tufts, T. Scott |
Kimbel & section 2036.(Kimbell 93 AFTR 2d 2004-2400 (CA-5, 5/20/04), section 2036 (a))(case study analysis) | Business | Collier, Robert Don, Denham, Michel A. |
Losses incurred during tax year in which shareholder files for bankruptcy.(current developments)(Williams 123 TC No.8 (2004))(case study analysis) | Business | Looney, Stephen R., Klein, I. Steven |
LTR revokes prior LTR that treated non-resident partners U.S sources income as exempt from U.S Taxation.(current developments)(Ltr. Rul. 200420012) | Business | Looney, Stephen R., Klein, I. Steven |
Noel B. Cunningham.(Director, Graduate Tax Program, New York University School of Law)(Interview) | Business | August, Jerald David |
Partnership's assumption of partner liabilities. | Business | Manning, Elliott |
Partners may exclude COD income in connection with partnership's chapter 11 bankruptcy.(current developments)(cancellation of debt income) | Business | Looney, Stephen R., Klein, I. Steven |
Proposed regulations on adjustments to NUBIG.(current developments)(net unrealized built-in gain) | Business | Looney, Stephen R., Klein, I. Steven |
Proposed regulations require converting corporations to look through partnerships for purposes of computing LIFO recapture tax. | Business | |
S Corporations & partial liquidations: Two favorable tax regimes. | Business | Collins, Bryan P., Starr, Samuel P., Braithwaite, F. Howard |
Small steps versus radical action.(subchapter S, reforms and replacements of contents) | Business | August, Jerald David, Hall, C. Wells, III, Siegel, William R. |
Some comments on single member LLCs and section 1031 exchanges.(Limited Liability Company) | Business | Cuff, Terence Floyd |
'Son of boss' meets 'Annie get your gun': a cautionary tale. | Business | Postlewaite, Philip F. |
State non-resident composite income tax returns can provide simplicity, but at a cost. | Business | Smith, Patrick H., W., McLoughlin Micheal |
State tax treatment of limited liability companies and limited liability partnerships. | Business | Ely, Bruce P., Grissom, Christopher R. |
Successful defense to an IRS section 2036(a) attack: estate of E. Stone III.(Internal Revenue Service)(Family Limited Partnership)(Rul. 93-12) | Business | Mezzullo, Louis A |
Surviving a section 2036(a)(2) attack. | Business | Pratt, David, Zakin, Jennifer E. |
Tangible guidance on intangibility.(new tax law section 263) | Business | Nellen, Annette, Purcell, Tom |
Tax advisor's privilege and section 7525.(tax law section 7525) | Business | Dawson, James P. |
Taxpayer's valuation rejected for purposes of built-in gain tax.(Garwood Irrigation Company ) | Business | |
Temporary regulations on deemed elections to be an association by S corporations.(current developments) | Business | Looney, Stephen R., Klein, I. Steven |
The entity choice decision for owners of closely held firms. | Business | Cunningham, Donald F., Erickson, Paul |
The tax-free environment S Corporation ESOPs and the perils of anti-abuse rules.(employee stock ownership plans) | Business | Grussing, Bruce, Lenczewski, Susan |
To foil filching from the federal FISC: A test to thwart (some) shelters. | Business | Lurie, Alvin D. |
Uneasy balance: congress battles treasury over cash balance rules. | Business | Lurie, Alvin D. |
Valuation of interests 'in transit' in family limited partnerships: Part 3. | Business | August, Jerald David, Maxfield, Guy B. |
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