Add to ORKGThe dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital importance to any corporation that is subject to the accumulated earnings tax or the personal holding company tax. Either of these taxes, if applicable, is imposed in addition to the federal income taxes otherwise payable by the corporation. Since the accumulated earnings tax is substantial and the personal holding company tax is downright confiscatory, a corporation must do whatever is necessary legally to avoid paying these additional taxes. A corporation subject to either of the taxes generally can avoid them only by taking advantage of the dividends paid deduction, which directly reduces the income subject to the taxes. This article analyze...
There have been various proposals made in the past two decades to integrate the corporate and shareh...
In an effort to make an amount distributed to its shareholders tax deductible, taxpayer bought utili...
In the case of Towne v. Eisner, the United States Supreme Court has recently held that under the Inc...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
Ordinarily, distributions by a personal holding company qualify for the dividends paid deduction onl...
The difficulty of determining whether payments made by a corporation on its securities are dividends...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Modern dividend statutes, as exemplified by the Model Business Corporation Act, have incorporated ma...
Professor Blum advocates repeal of the earnings and profits limitation on dividend income. Profess...
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
There have been various proposals made in the past two decades to integrate the corporate and shareh...
In an effort to make an amount distributed to its shareholders tax deductible, taxpayer bought utili...
In the case of Towne v. Eisner, the United States Supreme Court has recently held that under the Inc...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
Ordinarily, distributions by a personal holding company qualify for the dividends paid deduction onl...
The difficulty of determining whether payments made by a corporation on its securities are dividends...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Modern dividend statutes, as exemplified by the Model Business Corporation Act, have incorporated ma...
Professor Blum advocates repeal of the earnings and profits limitation on dividend income. Profess...
The taxation of corporate distributions and shareholder gain is an area of the Internal Revenue Code...
This Article suggests that although one part of a corporate distribution may be analogous to a sale ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
There have been various proposals made in the past two decades to integrate the corporate and shareh...
In an effort to make an amount distributed to its shareholders tax deductible, taxpayer bought utili...
In the case of Towne v. Eisner, the United States Supreme Court has recently held that under the Inc...