ACM Partnership: contingent installment sale transaction lacked economic substance

Article Abstract:

Colgate-Palmolive Co was found guilty by a tax court of entering into a series of well-coordinated deals, through ACM Partnership, to exploit a flaw in contingent installment sales regulations that would produce considerable spurious capital losses. The court established that the partnership's endeavors waere wanting in economic substance. The case shows that corporate taxpayers continue to accept the aggressive tax shelter tactics that are marketed to them.

Public Finance Activities, Corporate Tax Administration, Corporate Income Taxes, Evaluation, Laws, regulations and rules, Tax administration, Tax shelters

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Administration's Proposal to Tax C to S Conversions Requires Constant Monitoring

Article Abstract:

This paper examines the legal consequences of the administrations proposal to tax conversions of C corporations to S corporations and also the proposal of the Internal Revenue Service to tax conversions of S corporations to partnerships.

Partnerships, Partnership, S corporations

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ACM Partnership: Contingent Installment Sale Transaction Lacked Economic Substance

Article Abstract:

When ACM Partnership applied temporary regulations allowing contingent installment sales, the Tax Court disallowed transactional losses for being sham, i.e., for lack of economic substance and serving no useful nontax purposes.

Cases, Colgate-Palmolive Co., CL, MER, Tax evasion, Merrill Lynch & Company Inc., Algemene Bank Nederland N.V., ACM Partnership

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