| Business Entities 2005 |
| Title | Subject | Authors |
|---|
| Allocation of stock redemption proceeds to principal does not terminate OSST status of trusts.(current developments) | Business | Looney, Stephen R., Klein, Steven I. |
| Carol Kulish Harvey.(director, Deloitte Tax LLP's Washington National Tax Office Joint Venture and Passthrough Service Group)(Interview) | Business | August, Jerald David |
| C corporations - interest deductions disallowed.(current developments)(Indmar Products Co., Inc., TCM 2005-32) | Business | Looney, Stephen R., Klein, Steven I. |
| Corporations - Corporation's AMT NOL carryback reduced by its taxable income in pre-AMT tax years.(Sequa Corp's alternative minimum tax) | Business | Looney, Stephen R, Klein, Stephen I |
| Corporations/Corporations - Property to be valued are business assets contributed to limited partnership not LP units.(Pope and Talbot Inc.) | Business | Looney, Stephen R, Klein, Stephen I |
| Corporations - Partial liquidation treatment for distribution derived from liquidation of subsidiary after sale of subsidiary's business. | Business | Looney, Stephen R, Klein, Stephen I |
| Corporations - redemption of founder's stock qualified as a termination of shareholder's interest.(current developments)(Hurst, 124 TC No.2 (2005), HMI) | Business | Looney, Stephen R., Klein, Steven I. |
| Corporations - Second circuit adopts "firm and fixed plan" test for purposes of integration of transactions.(Merrill Lynch and Company Inc.) | Business | Looney, Stephen R, Klein, Stephen I |
| Current developments. | Business | Harvey, Carol Kulish, Browne, Patrick, Kwon, Michelle |
| Current developments.(amendments made to tax regulations by the Internal Revenue Service) | Business | Looney, Stephen R., Klein, Steven I. |
| Current developments.(Internal Revenue Service, Department of the Treasury, tax policy, S corporations, partnerships, corporations) | Business | Harvey, Carol Kulish, Tod, Jim, Kwon, Michelle M. |
| Dennis L. Belcher.(partner of McGuire Woods LLP.)(Interview) | Business | August, Jerald David |
| Disguised sales of partnership interests.(proposed regulations of internal revenue service, tax treatment)(Cover Story) | Business | Ringer, Jeffrey L. |
| Dispositions and forfeitures on nonvested partnership interests for services rendered under section 83. | Business | Harris, Richard W. |
| Disregarded entities are separate from owner for purposes of federal tax liabilities.(current developments) | Business | Looney, Stephen R., Klein, Steven I. |
| Enhanced reporting penalties.(American Jobs Creation Act of 2004)(tax shelter provisions) | Business | Shaw, Richard A. |
| Exclusion of capital gain on sale of QSB stock.(qualified small business) | Business | Levy, Melanie Warfield |
| FERC reexamines treatment of income taxes as recoverable costs for flow-through entities.(Federal Energy Regulatory Commission)(BP West Coast Products, LLC v. FERC, City of Charlottesville v. FERC) | Business | Ely, Bruce P., Komarow, Jeffrey D. |
| Final regs confirm that COI and COBE requirements do not apply to "E" and "F" reorganizations.(current developments)(continuity of interest, continuity of business enterprise) | Business | Looney, Stephen R., Klein, Steven I. |
| Guess who's coming to dinner.(trustee's powers, bankruptcy of an LLC member)(In re Ehmann) | Business | Rutledge, Thomas E., Geu, Thomas Earl |
| IRS rules that stock issuance costs must be netted against stock proceeds.(current developments)(Internal Revenue Service)(Indopco, Inc., Supreme Court) | Business | Looney, Stephen R., Klein, Steven I. |
| IRS section 2036 assault continues on family limited partnerships.(2036(a))(Internal Revenue Service) | Business | August, Jerald David, Dawson, James, Maxfield, Guy |
| Limited liability company conversions - Navigating the state tax implications. | Business | Smith, Kelly W., Harringer, Karen M. |
| Merger of parent into disregarded LLC subsidiary of newly formed corporation treated as "F" reorganization.(current developments) | Business | Looney, Stephen R., Klein, Steven I. |
| "Net value" proposed regulations address insolvency/no net value in various corporate transactions.(current developments) | Business | Looney, Stephen R., Klein, Steven I. |
| New section 409A makes deferred compensation a whole new ball game.(American Jobs Creation Act of 2004) | Business | Lurie, Alvin D. |
| Partnership provisions of the American Jobs Creation Act of 2004. | Business | Melone, Matthew A. |
| Partnerships - District Court allows shifting of taxable income to foreign partners.(General Electric Capital Corp.) | Business | Looney, Stephen R, Klein, Stephen I |
| Partnerships - IRS finds method of allocation of excess nonrecourse liabilities inappropriate.(Internal revenue service) | Business | Looney, Stephen R, Klein, Stephen I |
| Partnerships - IRS revokes rev. rule 2004-43 and will issue anti-mixing bowl regulations.(current developments)(Internal Revenue Service, gain or loss from assets-over merger in partnerships) | Business | Looney, Stephen R., Klein, Steven I. |
| Planning tax advice under circular 230 and the Jobs Act.(American Jobs Creation Act 2004) | Business | Shaw, Richard A. |
| Proposed regulations deal with partnership's assumption of partner 'liabilities' part 2. | Business | Manning, Elliott |
| Recent developments in partnership taxation. | Business | Rubin, Blake D., Finkelstein, Jon G., Scala, Josh |
| Recent developments in partnership taxation: part 1.(sections 1202 and 1045) | Business | Rubin, Blake D., Finkelstein, Jon G., Scala, Josh |
| Recent developments in partnership taxation: part 2.(tax regulations with respect to audits and accounting in partnerships) | Business | Rubin, Blake D., Finkelstein, Jon G., Scala, Josh |
| Repatriation of foreign earnings after the American Jobs Creation Act of 2004. | Business | Loizeaux, James D. |
| Restructuring of S corporation into limited partnership and limited liability company treated as "E" and "F" reorganizations.(current developments) | Business | Looney, Stephen R., Klein, Steven I. |
| Robert Panoff.(Robert E Panoff firm, corporate tax shelters) | Business | August, Jerald David |
| S corporation rules liberalized by the American Jobs Creation Act of 2004. | Business | Melone, Matthew A. |
| S corporations - Filing of bankruptcy petition does not terminate corporation's S election. | Business | Klein, Steven I, Looney, Stephen R |
| S corporations - IRS rules that five year waiting period to re-elect S status not applicable.(current developments)(Internal Revenue Service) | Business | Looney, Stephen R., Klein, Steven I. |
| S Corporations - Taxpayers could not net income and loss from property rentals to S corporations. | Business | Looney, Stephen R, Klein, Stephen I |
| Section 470 and pass-thru entities: a problem in need of a solution.(American Jobs Creation Act of 2004) | Business | Harvey, Carol Kulish, Sowell, James B., Browne, Patrick J. |
| Single purpose entities give borrowers more leverage.(suggestions for drafting the documents to form an SPE) | Business | Rowell, Robert K. |
| Some practical aspects of undertaking a reverse exchange.(like kind exchanges) | Business | Cuff, Terence Floyd |
| Structuring joint ventures between for-profit and tax-exempt entities. | Business | Dalton, Thomas M |
| Tax courts rejects "bad faith" requirement as prerequisite to finding disguised dividend.(current developments)(Menard, Inc. TCM 2005-3) | Business | Looney, Stephen R., Klein, Steven I. |
| The balance shifts: cash balance support from the Hill.(Capitol Hill) | Business | Lurie, Alvin D. |
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