Add to ORKGSection 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorganization to treat any gain recognized as a dividend, if the reorganization has the effect of the distribution of a dividend. This article examines the conflicting interpretations of this section and offers suggested changes in the law. The article also reviews the performance of all three branches of government in developing tax law
The purposes of this Article are to examine whether there is any longer a reason for concern because...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorga...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Acquisitive reorganizations either by consolidation or statutory merger have become a popular means ...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code...
The differences in the tax treatment of dividends and redemptions, the tax goals of individual and c...
A stock-for-stock reorganization which qualifies under IRC section 368(a)(1)(B) accords tax-free tre...
The purposes of this Article are to examine whether there is any longer a reason for concern because...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorga...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Acquisitive reorganizations either by consolidation or statutory merger have become a popular means ...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Stock and securities of controlled corporations may be distributed to shareholders, tax free, in cas...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code...
The differences in the tax treatment of dividends and redemptions, the tax goals of individual and c...
A stock-for-stock reorganization which qualifies under IRC section 368(a)(1)(B) accords tax-free tre...
The purposes of this Article are to examine whether there is any longer a reason for concern because...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...