Journal of Taxation of Investments |
Title | Subject | Authors |
Abandoning interests may save taxes for investors in troubled partnerships. | Law | Witner, Larry, Rosenberg, Donald L. |
Administrative proposals point to changes for pass-through entities. | Law | Altamura, Anthony, Dreyfus, James K. |
Aftermath of INDOPCO: the Service applies the future benefit test for capital expenditures. (INDOPCO, Inc. v. Commissioner) | Law | McKenna, Matthew M., McGill, Sarah L. |
Amortizing bond premiums can provide tax savings for investors. | Law | Persellin, Mark B., Novak, E. Shawn |
Applying the uniform capitalization rules to oil and gas properties. | Law | Hineman, Thomas G. |
Audit guidelines and a correction program focus on section 403(b) plans. | Law | Lerner, Deborah M., Hoffman, Susan K. |
Brown Group shows interplay between Subpart F and partnership provisions. | Law | Krauthamer, Nina |
Computing shareholder advantage where RIC retains income. (regulated investment company) | Law | Calvin, James N. |
Congress considers tax relief for debt restructurings. | Law | Nolan, Matthew N. |
Convertibility and consolidated returns highlight recent developments. | Law | Willens, Robert |
Corporate finance vehicles: debt related issues. | Law | Willens, Robert |
Covered calls can provide tax and financial advantages. | Law | Fink, Philip R., McCrudden, John |
Debt restructuring rules favor the insolvent. | Law | Haubert, William J. |
Deciphering the taxation of credit derivatives. | Law | Haspel, Ahron H., Bush, John N. |
Deferring gains on corporate investments through the use of redemptions. | Law | Abahoonie, Edward J., Fichtenbaum, Mark |
Derivatives continue to present tax-planning opportunities for cross-border investments. | Law | Carlisle, Linda E., Lanning, Geoffrey B. |
Derivatives trading now has a "safe harbor.".(taxation) | Law | Carlisle, Linda E. |
Developments affecting contingent value rights, straddles, and redemptions. | Law | Willens, Robert |
Do tax-free municipal bonds sometimes pack a taxable surprise for high-net-worth investors? | Law | Harrison, Robert E. |
Economic performance rules contain elections for real estate developers. | Law | Bird, Bruce M., Segal, Mark A. |
Employers face increasing questions about corporate-owned life insurance. | Law | McCormick, Hugh T., Bell, Michael A. |
Equity index swaps: an uncertain future. | Law | McKenna, Matthew M., McGill, Sarah L. |
Estate planning: planning for retirement plan benefits. | Law | Rothberg, Richard S., Ritter, Paul M. |
Final passive activity regs. include favorable and unfavorable changes for taxpayers. | Law | Grace, Michael J. |
Final regs. clarify but do not fundamentally alter rental real estate activity rules. | Law | Grace, Michael J. |
Final regulations add new clarifications for publicly traded partnerships. | Law | Altamura, Anthony, Dreyfus, James K. |
Final regulations simplify S corporation one-class-of-stock rule. | Law | Burkhard, James R. |
Final regulations soften the rules on conversion transactions. | Law | Willens, Robert |
Final regulations sound the death knell for retirement CDs. | Law | McCormick, Hugh T., Bell, Michael A. |
Final regulations under section 382 clarify taxation of options. | Law | Haspel, Ahron H., Bush, John N. |
Financial success after stardom: tax planning for professional athletes. | Law | Harris, Carole |
Foreign currency straddles: bifurcation of foreign currency gain or loss from economic gain or loss. | Law | Farias, Christopher D. |
Foreign irrevocable life insurance trusts can save estate and income tax. | Law | Rosen, Howard D. |
Forming a foreign sales corporation can shield rental income from tax. | Law | Manwell, Edmund R. |
Internal Revenue Service proposes regulations on qualified domestic trusts. | Law | Krauthamer, Nina |
International matters: section 482 proposed regulations alter transfer pricing for tangible property. | Law | Krauthamer, Nina |
International trade legislation modifies taxation of some partnership distributions. | Law | Altamura, Anthony |
Intrafamily sales of appreciated assets offer attractive wealth transfer opportunities. | Law | Hamill, James R. |
Investing in Mexico: from a Mexican practitioner's view. | Law | Krauthamer, Nina, Kiehnle, Herman |
Investment partnerships receive guidance from final regs on distribution of marketable securities. | Law | Kess, Kenneth M. |
Issuance of final regulations under Section 351 will not resurrect exchange funds. | Law | Kess, Kenneth M. |
Master/feeder structures, foreign tax credit preferred stock. (mutual fund management) | Law | Calvin, James N. |
More guidance is needed on master/feeder fund earnings and profits. | Law | Kess, Kenneth M. |
Multi-tier partnerships can pay general partners for results and avoid guaranteed payments. | Law | Axelrad, Jonathan |
Municipal bond and other interest rates could be seriously affected by potential tax law changes. | Law | Williamson, James E. |
Mutual funds can use stock redemptions to meet distribution requirements. | Law | Kess, Kenneth M. |
Mutual funds may face problems unless they defer all post-October capital losses. | Law | Kess, Kenneth M. |
Mutual funds: ordinary-capital mixed straddle treatment should avoid character conversion. | Law | Calvin, James N. |
New direct rollover and withholding rules require plan amendment. (pension funds) | Law | Hoffman, Susan Katz, Lerner, Deborah M. |
New York Court of Appeals adds new wrinkle to international taxation of estates. | Law | Krauthamer, Nina |
NPCs and contingent debt instruments have the same economics, but different rules. (notional principal contracts) | Law | Carlisle, Linda E., Lanning, Geoffrey B. |
Oil and gas investments: the depletion tax preference controversy. | Law | Hineman, Thomas G. |
Passive activities: coordination of sections 469(g) and 163. | Law | Grace, Michael J. |
Passive foreign investment company rules are complex and unforgiving. | Law | Fox, Stephen C., Feinschreiber, Robert |
Plan distributions to nonresident aliens. | Law | Hoffman, Susan Katz, Lerner, Deborah M. |
Proposals would allow checking the box, but tax shorts against the box. | Law | Altamura, Anthony, Dreyfus, James K., Moreno, Margarita M. |
Proposed cross-border securities lending rules leave unanswered questions. | Law | Colon, Jeffrey M. |
Proposed regulations allow aggregation of limited partner interests. | Law | Grace, Michael J. |
Proposed regulations create problems for retirement CDs. (certificates of deposit) | Law | McCormick, Hugh T. |
Proposed regulations narrow consistency rules on stock and asset acquisitions.. | Law | Haspel, Ahron H., Bush, John N. |
Proposed regulations provide guidance on modifications of debt instruments. | Law | Nolan, Matthew M. |
Proposed regulations would tax conduits as true lenders. | Law | Krauthamer, Nina |
Qualifying business units can save taxes and trouble for single country funds . | Law | Calvin, James N. |
Recent cases and rulings clarify activity determinations and other issues. (passive activities) | Law | Grace, Michael J. |
Recent developments address OID and dividends-received deduction. (original issue discount) | Law | Willens, Robert |
Recent developments affecting cancellation of debt income, bankruptcy estates, and investment interest. | Law | Grace, Michael J. |
Recent developments and legislative outlook. (Passive Activities) | Law | Grace, Michael J. |
Recent developments. (Corporate finance vehicles) | Law | Willens, Robert |
Recent developments create concern for split-dollar life insurance. | Law | McCormick, Hugh T., Bell, Michael A. |
Recent developments relating to Section 482 and tax treaties. (IRC Section 482) | Law | Krauthamer, Nina |
Recent service rulings limit affirmative use of deemed dividend rules. | Law | Stodghill, LaBrenda Garrett |
Retirement CD blends annuity and bank deposit and leaves tax treatment ambiguous. | Law | McCormick, Hugh T. |
Seagram case and Seagram's actions highlight current developments. | Law | Altamura, Anthony, Dreyfus, James K. |
Securities lending transactions can have uncertain tax results. | Law | Haspel, Ahron H., Bush, John N. |
Service makes it easier to tax options on stock indices as section 1256 contracts. | Law | Kess, Kenneth M. |
Shareholder tax savings highlight recent transactions. | Law | Willens, Robert |
Short-term currency gains need not disqualify a RIC. (regulated investment company) | Law | Calvin, James N. |
Small Business Job Protection Act of 1996: impact on investors. | Law | Altamura, Anthony, Dreyfus, James K. |
Structuring and taxing the FSC leasing transaction. (foreign sales corporation) | Law | Manwell, Edmund R. |
Supreme Court excludes tangible property from adjusted basis of mineral deposit for AMT purposes. (alternative minimum tax in United States v. Hill) | Law | Hineman, Thomas G. |
Tax benefits of giving an IRA to charity. | Law | Whittenburg, G.E., Williamson, James E., Oestreich, N.A. |
Tax considerations in selecting commodity and securities trading entities. | Law | Carlisle, Linda E. |
Tax considerations in selecting commodity and securities trading entities and advisers. | Law | Carlisle, Linda E., Swainston, Kurt C. |
Tax Court finds a related-party rule in Section 265(a)(2). | Law | Carlisle, Linda E., Kaplan, Jason W. |
Tax Court rejects IRS sourcing rule for royalty income. | Law | Krauthamer, Nina |
Tax treatment of substitute payments under securities lending and sale repurchase transactions. | Law | Carlisle, Linda E., Lanning, Geoffrey B. |
The Cottage Savings regulations. (modifications of debt instruments) | Law | McKenna, Matthew M., McGill, Sarah L. |
The Service seeks increased enforcement of tax-sheltered annuities. | Law | Hoffman, Susan Katz, Lerner, Deborah M. |
This time around, the Eighth Circuit comes down with a reversal of Brown. | Law | Krauthamer, Nina |
Today's R&D venture requires hands-on investing. (research and development) | Law | Oliver, Joseph R. |
TRA '97 changes in option strategy, anti-dividend stripping rules highlight recent developments. (Taxpayer Relief Act of 1997) | Law | Willens, Robert |
TRA '97 makes major changes to ELP audit procedures.(electing large partnerships; taxation) | Law | Melone, Matthew A. |
Treasury grapples with subpart F branch rule and 'hybrid branches.' | Law | Krauthamer, Nina |
Troubled insurance companies - IRS rulings. | Law | Schorr, Jonathan M., McCormick, Hugh T. |
Using a "call" option straddle to maximize cash dividend yield. | Law | Calvin, James N. |
What's left of the single economic interest theory? (foreign entities as corporations or partnerships) | Law | McKenna, Matthew M., McGill, Sarah L. |
What the anti-money laundering initiative means to the average (non-criminal, non-terrorist) investor/taxpayer. | Law | Ensminger, John |
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