Related corporations and triangular dividends: can the circle be squared?

Article Abstract:

Triangular dividends should be found for transactions between affiliated corporations when the primary motive for entering the transaction had no valid business purpose. Triangular dividends are a type of constructive dividend that can result in the taxation of the shareholders controlling the affiliated corporations. The IRS has failed to provide taxpayers with guidance on this doctrine, and it has taken the position that all transfers for less that adequate consideration result in constructive dividends.

Affiliated corporations, Dividends, Securities, Related party transactions

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The taxation of split-dollar life insurance: a solution to the dilemma

Article Abstract:

The continued uncertainty surrounding the income taxation of the equity build-up in split-dollar life insurance arrangements could be resolved by treating such policies like interest-free loans under IRC section 7872. Practitioners have found the IRS's use of section 83 to determine the taxation of split-dollar plans unsatisfactory. Use of section 7872 would better recognize the economic and tax principles implicit in the use of split-dollar arrangements.

Life Insurance, Direct Life Insurance Carriers, Split-dollar life insurance, Split dollar life insurance

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Stock redemptions, attribution rules and related parties: the tax maze for estates and trusts

Article Abstract:

In determining the tax liability of a corporation that redeems its stock, attribution rules are used to determine the stock's legal owner. These rules' applications to trusts and decedents' estates are examined.

Legal issues & crime, Government regulation (cont), Government regulation, Taxes, Legal/Government Regulation, Trusts, Funds, Trusts, and Other Financial Vehicles, Capital Management-Stock Repurchase, Laws, regulations and rules, Decedents' estates, Trusts and trustees, Trustees, Trusts (Law), Stock redemption, Attribution rules (Taxation)

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