This Article discusses the requirements of section 302(b) for characterizing a stock redemption as a purchase rather than as a dividend equivalent. The focus is primarily on two issues: (1) whether the election authorized by section 302(c)(2) to waive family attribution rules should be available to an entity such as a trust or estate; and (2) the determination of the standards to be applied in resolving whether a redemption is not essentially equivalent to a dividend so that section 302(b)(1) is applicable
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
After the adoption of partial integration in 2003, there has been only a modest rise in dividends, b...
The Model Business Corporation Act (hereinafter the Model Act ) has been in existence for more than...
This Article discusses the requirements of section 302(b) for characterizing a stock redemption as a...
This Article reviews the redemption provisions of both section 302 and section 304 of the Internal R...
This article looks into the situation in which Section 303 is beign planned for use in a corporation...
The enactment of the Economic Recovery Tax Act of 1981 (hereinafter referred to as the 1981 Act ) w...
One of the questions remaining unanswered after United States v. Davis is whether loss of control ov...
Generally, proceeds received by shareholders for a corporation\u27s redemption of its own stock are ...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Corporation statutes and accounting principles have traditionally dictated that cash dividends to st...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
The allocation of stock dividends received by a trustee to either income or corpus has been a recurr...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
After the adoption of partial integration in 2003, there has been only a modest rise in dividends, b...
The Model Business Corporation Act (hereinafter the Model Act ) has been in existence for more than...
This Article discusses the requirements of section 302(b) for characterizing a stock redemption as a...
This Article reviews the redemption provisions of both section 302 and section 304 of the Internal R...
This article looks into the situation in which Section 303 is beign planned for use in a corporation...
The enactment of the Economic Recovery Tax Act of 1981 (hereinafter referred to as the 1981 Act ) w...
One of the questions remaining unanswered after United States v. Davis is whether loss of control ov...
Generally, proceeds received by shareholders for a corporation\u27s redemption of its own stock are ...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Corporation statutes and accounting principles have traditionally dictated that cash dividends to st...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
The allocation of stock dividends received by a trustee to either income or corpus has been a recurr...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
After the adoption of partial integration in 2003, there has been only a modest rise in dividends, b...
The Model Business Corporation Act (hereinafter the Model Act ) has been in existence for more than...