| Journal of Corporate Taxation 1998 |
| Title | Subject | Authors |
|---|
| Calculation of consolidated taxable income: the treatment of specified liability losses. | Law | Collins, Bryan P., Garrett, Lawrence M., O'Brien, Bonnie A. |
| Continuity representation discontinued.(IRS rules regarding continuity of legal interest applicable in corporate reorganizations) | Law | Bloom, Gilbert D. |
| Federal Circuit rules that allocation of earnings and profits in intra-group spin-off does not support increased basis. | Law | Friedrich, Craig W. |
| Goldilocks meets Private Letter Ruling 9809051.(IRS ruling on partial liquidations and spin-offs) | Law | Bloom, Gilbert D. |
| "Greenmail" held not deductible but possibly amortizable by district court. | Law | Friedrich, Craig W. |
| Incentive stock options in the S corporation context. | Law | Samsa, Mary K. |
| IRA distributions to nonresident aliens: a treaty analysis.(tax treaties) | Law | Ellis, David W. |
| IRS rules that current deductibility of training costs not affected by INDOPCO. | Law | Friedrich, Craig W. |
| Kohler v. United States - application of Section 1504(d). (includes discussion of Trinova and IU International cases) | Law | Collins, Bryan P., Garrett, Lawrence M., Tucker, Howard J. |
| Letter Ruling 9719036 - ruling letters rush in where opinion letters fear to tread. | Law | Bloom, Gilbert D. |
| Letter Ruling 9720007 - the "risky business" business purpose and a bit more. | Law | Bloom, Gilbert D. |
| New section 351(e): the "not an investment company" representation for section 351 private letter ruling requests just got tougher. (Internal Revenue Code section 351) | Law | Bloom, Gilbert D. |
| "Not quite proper stock": section 351(g) raises a number of new questions.(IRC s. 351(g)) | Law | Rizzi, Robert A., Fattman, Stephen P. |
| Required beginning date for qualified plan distributions. | Law | McBreen, Maura Ann |
| Retirement plan provisions of the Taxpayer Relief Act. (Taxpayer Relief Act of 1997) | Law | McBreen, Maura Ann |
| Stalking the elusive qualified stock purchase. | Law | Bloom, Gilbert D. |
| Tax Court finds anticipatory assignment of income on charitable contribution made "too late" during plan for cash tender offer and downstream merger. | Law | Friedrich, Craig W. |
| Technical Advice Memorandum 9743001 and the step transaction doctrine: integrate, separate, separate. | Law | Bloom, Gilbert D. |
| Temporary regulations: application of Section 382 to a consolidated group. | Law | Collins, Bryan P., Garrett, Lawrence M., Tucker, Howard J. |
| The foreign sales corporation: optimizing the benefits. | Law | Olin, Jeffrey L. |
| Timing deductions around a short year. | Law | Miller, Joel E. |
| Treatment of hybrid arrangements under Subpart F.(hybrid business entities, IRC Subpart F) | Law | Engle, Howard S. |
| U.S. taxation of foreign nationals. | Law | Crist, Bruce, Klaus, Kenton J., Cohen, Lorraine E. |
| U.S. taxation of foreign nationals. (part 2) | Law | Crist, Bruce, Klaus, Kenton J., Cohen, Lorraine E. |
| Work product protection from discovery upheld for document that analyzed outcome of anticipated litigation.(IRS litigation) | Law | Friedrich, Craig W. |
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