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Final regulations add new clarifications for publicly traded partnerships

Article Abstract:

The final IRS regulations released under IRC section 7704 clarify definitional issues raised by the proposed regulations and reduce the risk that partnerships could be classified as publicly traded without participating in any markets. The final regulations differ from the proposed regulations in a number of ways including the increased reliance on the facts and circumstances test. The regulations also address safe harbor, private placement and private transfer issues. Ten years of transition relief is provided for partnerships active before Dec. 4, 1995.

Author: Altamura, Anthony, Dreyfus, James K.
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1996
Partnership, Partnerships, Private placements (Securities)

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Small Business Job Protection Act of 1996: impact on investors

Article Abstract:

The Small Business Job Protection Act of 1996 was signed by Pres Bill Clinton on Aug 20, 1996, and contains a number of provisions which could be important to investors. These relate mainly to S corporations and include an increase in the permissible number of shareholders, the possibility of electing a small business trust, and an expansion of the post-termination transition period. Other provisions are summarized.

Author: Altamura, Anthony, Dreyfus, James K.
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1997
Human resource management, Small business, S corporations, Corporate divestiture, Divestiture

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Subjects list: United States, Taxation
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