Journal of Corporate Taxation 1996 |
Title | Subject | Authors |
401(k) wraparound arrangements. | Law | Navin, Patrick T. |
Allocation of research and experimentation expenditures between U.S.-source and foreign-source income - final regulations. | Law | Engle, Howard S. |
Benefits of customs planning.(International Developments) | Law | Engle, Howard S. |
Clouds gathering over corporate equity split-dollar insurance plans. | Law | Bernstein, Robert S., Buss, Adam J. |
Contingent liabilities in section 351 transactions: the IRS limits the application of Holdcroft. | Law | Matthias, Steven K. |
Contingent payments amounting to 25 percent of total payments for trademarks found to be "substantial" and therefore deductible under section 1253.(IRC section 1353)(Recent Developments) | Law | Friedrich, Craig W. |
Contributions to capital under section 108(e)(6): the last frontier. | Law | Rizzi, Robert A. |
Controlled foreign corporations: proposed regulations deal with Subpart F and foreign personal holding company income. | Law | Engle, Howard S. |
Derivatives and continuity of interest: risk management raises new issues for reorganizations. | Law | Rizzi, Robert A. |
Distribution of stock received upon merger by partnership does not violate continuity of interest required of tax-free reorganizations. | Law | Friedrich, Craig W. |
DOL issues draft guidance for providing investment-related materials to participants in tax-qualified retirement plans. | Law | Wydajewski, Brian K. |
Election and statement requirements proliferate. | Law | Collins, Bryan P. |
Float like a deemed butterfly ... reflections on the significance of meaninglessness in a "B" reorganization. | Law | Friedel, David B. |
Form 5471 revisions.(IRS information return for U.S. persons with respect to certain foreign corporations)(International Developments) | Law | Engle, Howard S. |
Gifting stock options. | Law | Bernstein, Robert S., Buss, Adam J. |
Impact of the Xerox case on the computation of the deemed-paid foreign tax credit from UK corporations. | Law | Engle, Howard S. |
Imputed benefit accrual service. | Law | McBreen, Maura Ann |
International aspects of the 'check the box' partnership classification procedure.(International Developments) | Law | Engle, Howard S. |
IRS invites comments on clarifying the effect of INDOPCO on current deductibility. | Law | Friedrich, Craig W. |
IRS rules that severence pay remains currently deductible after INDOPCO.(Recent Developments) | Law | Friedrich, Craig W. |
Letter Ruling 9508009 - busting a "B": why and how? | Law | Bloom, Gilbert D. |
Letter Ruling 9535053: little ado about something? | Law | Bloom, Gilbert D. |
Letter Ruling 9605012: what liquidation? (liquidation-reincorporation) | Law | Bloom, Gilbert D. |
New section 367 temporary regulations. | Law | Engle, Howard S. |
Redemption distribution treated as dividend reduces S corporation's accumulated adjustments account.(Recent Developments) | Law | Friedrich, Craig W. |
Snap shots, successive ownership changes, and other section 382 traps. | Law | Rizzi, Robert A. |
Standard plan amendment provision upheld. | Law | Wydajewski, Brian K. |
Treasury announces delay in proposed effective date of proposal making conversion of "large" C corporations to S corporations and further extends proposal. | Law | Friedrich, Craig W. |
Two questionable spin-off rulings. | Law | Bloom, Gilbert D. |
Value of appreciated assets held measure of section 311(d) gain.(IRC section 311(d))(Recent Developments) | Law | Friedrich, Craig W. |
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