| Journal of Corporate Taxation 1993 |
| Title | Subject | Authors |
|---|
| Ability to have a triangular acquisition is restricted. (I.R.S. Technical Advice Memorandum 9215005) | Law | Bloom, Gilbert D. |
| Are expenses incurred in obtaining LBO loans deductible? (leveraged buyout) | Law | Bernstein, Robert S., Akselrad, Ira |
| Bank holding company/bank combinations. (I.R.S. Private Letter Ruling 9240026) | Law | Bloom, Gilbert D. |
| Capital assets: the inventory exception to Section 1221 revisited. (I.R.C.) | Law | Seetharaman, Ananth |
| Clearing the deck of Waterman Steamship: pre-reorganization dividends and assumption of shareholder debt. (corporate stock reorganizations and Commissioner v. Waterman S.S. Corp.) | Law | Rizzi, Robert A. |
| Decoding the uniform capitalization regulations applicable to manufacturers. | Law | Keeling, Kermit O., Sedaghat, Ali M. |
| Deemed dividends in cross-border Section 304 transactions. (dividend payments by a domestic corporation to a foreign corporation taxable under I.R.C. Section 304) | Law | Engle, Howard S. |
| Dual consolidated loss rules - final regulations. (losses of dual resident companies) | Law | Engle, Howard S. |
| Elective retroactive use of the Section 367 regulations. (I.R.S. Private Letter Ruling 9218062 on I.R.C. Section 367) | Law | Bloom, Gilbert D. |
| Exclusions from income for qualified individuals employed outside the United States. | Law | Budinger, Sandhya C. |
| Extension of U.S. stock plans to nonresident aliens. | Law | Navin, Patrick T. |
| Final Regulations under Section 512 - swap income and tax-qualified pension plans. (I.R.C.) | Law | Ellis, David W. |
| Foreign tax credit limitation rules. | Law | Engle, Howard S. |
| Front-end realignments: non-pro rata contributions of stock before corporate acquisitions. | Law | Rizzi, Robert A. |
| Liquidation coupled with some reincorporation. (I.R.S. Private Letter Ruling 9210041) | Law | Bloom, Gilbert D. |
| Liquidation distributions: the decision to utilize Section 453(h). | Law | White, Stephen J., Pratt, James W. |
| New proposed regulations limit the deemed exercise rule for options under Section 382. (I.R.C. Section 382 and loss corporation stock) | Law | Bernstein, Robert S., Akselrad, Ira |
| New rules concerning limitations on U.S. tax benefits from operations in restricted countries. (I.R.S. Revenue Rulings 92-62 and 92-63) | Law | Engle, Howard S. |
| Nontaxable purchase-price reduction versus taxable disposition - the interplay between Sections 108(e)(5) and 453B(f). (I.R.C.) | Law | Orefice, James A. |
| Proposed regulations apply section 163(j) to consolidated returns and other affiliated groups. | Law | Ferencz, Glenn E. |
| Quantity and quality in the substantially all requirement. (C, G and triangular corporate reorganizations) | Law | Rizzi, Robert A. |
| Retirement plan investments in company stock. | Law | McBreen, Maura Ann |
| Service asserts continued vitality of old Revenue Ruling but will not penalize consistent good-faith contrary positions. (I.R.S. Revenue Ruling 57-7) | Law | Friedrich, Craig W. |
| Sidestepping the business purpose test for corporate spin-offs. | Law | Agar, Raymond S., Tracy, Michael P. |
| Spin-off of newly formed subsidiary results in recapture of ITC. (investment tax credit and Salomon, Inc. v. U.S.) | Law | Friedrich, Craig W. |
| Stock acquisitions and liquidations by S corporations: availability of benefits afforded by sections 332 and 338. | Law | Zachary, Seth M., Weingold, Philip R. |
| Stock swap permitted? (I.R.S. Private Letter Ruling 9224016) | Law | Bloom, Gilbert D. |
| Taxation of foreign dividends. (Kraft Foods v. Iowa Department of Revenue) | Law | Engle, Howard S. |
| The brave new world of consolidated returns: an analysis of the recently proposed stock basis adjustment regulations. | Law | Collins, Bryan P., Nissley, P. Anthony, Morzorati, Lynn M., Tiedmann, William J. |
| The proposed Section 338 regulations: some good news from General Utilities repeal. (I.R.C.) | Law | Bridgeman, James D. |
| The tax-free entity under the U.S. flag: a U.S. Virgin Islands exempt company. | Law | Blum, William L. |
| The Treasury's debt modification regulations: Cottage Savings proves a perilous beacon. (Cottage Savings v. Commissioner) | Law | Friedrich, Craig W. |
| To B or not to B: distinctions between B and reverse triangular reorganizations defy logic but provide flexibility in restructuring. (corporate reorganizations) | Law | Rizzi, Robert A. |
| Transfer pricing: the new Section 482 temporary and proposed regulations. | Law | Engle, Howard S. |
| United States tax considerations in organizing a foreign joint venture. | Law | Parnes, Alan P. |
| What constitutes a change in accounting method: is it merely a timing question? | Law | Horvitz, Jerome S., Linton, Frank B. |
This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.
