Add to ORKGWhether income earned by an incorporated personal service business is taxable to the individual or to the corporation is often the subject of reallocation proceedings brought by the Internal Revenue Service. In this article the author discusses the theories underlying income reallocation and the applicable Internal Revenue Code sections, focusing on section 482. The author analyzes in detail the factors courts consider in permitting or denying reallocation and identifies the conflicts among the circuits in the interpretation and application of section 482
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code...
Whether income earned by an incorporated personal service business is taxable to the individual or t...
In evaluating potential abuses in the creation and operation of service corporations, the courts hav...
This article discusses C.I.R. v. Fender Sales, Inc., 338 F. 2d 924 (9th Cir. 1964). The author concl...
There are many small corporations, the ownership o fwhich is in the hands of a family group or a few...
The corporate form is often superior to other business structures because of the financial flexibili...
Tax-Fogelsong IV: THE SEVENTH CIRCUIT HOLDS THAT A PERSONAL SERVICE CORPORATION AND ITS SOLE SHAREHO...
By 1964, many years had elapsed since significant changes were made in the federal income tax treatm...
This Article traces the development of the nonentity and agency approaches to the treatment of nomin...
This article will analyze the proper application of the assignment of income doctrine to personal se...
The primary purpose of this article is to encourage closely held business owners and their lawyers t...
The corporate division, however, lends itself to schemes for avoidance of tax. These schemes are att...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code...
Whether income earned by an incorporated personal service business is taxable to the individual or t...
In evaluating potential abuses in the creation and operation of service corporations, the courts hav...
This article discusses C.I.R. v. Fender Sales, Inc., 338 F. 2d 924 (9th Cir. 1964). The author concl...
There are many small corporations, the ownership o fwhich is in the hands of a family group or a few...
The corporate form is often superior to other business structures because of the financial flexibili...
Tax-Fogelsong IV: THE SEVENTH CIRCUIT HOLDS THAT A PERSONAL SERVICE CORPORATION AND ITS SOLE SHAREHO...
By 1964, many years had elapsed since significant changes were made in the federal income tax treatm...
This Article traces the development of the nonentity and agency approaches to the treatment of nomin...
This article will analyze the proper application of the assignment of income doctrine to personal se...
The primary purpose of this article is to encourage closely held business owners and their lawyers t...
The corporate division, however, lends itself to schemes for avoidance of tax. These schemes are att...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code...