On December 10, 1969, the most massive and controversial piece of tax legislation ever proposed was enacted by Congress. One small portion of this act, § 421, has substantially altered the tax status of stock dividends by amending § 305 of the Internal Revenue Code of 1954. As a result, § 305 now covers a wide variety of situations where the receipt of stock dividends previously nontaxable will give rise to income taxable at ordinary rates
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
The difficulty of determining whether payments made by a corporation on its securities are dividends...
Federal income taxation of stock dividends has followed a diverse course. Since the introduction of ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
Allegations that stock dividends serve as a vehicle for deceptive financing, evasion of taxes, misle...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
In the case of Towne v. Eisner, the United States Supreme Court has recently held that under the Inc...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
The long awaited decision of the United States Supreme Court in Eisner v. Macomber (1920) 40 Sup. Ct...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
With higher corporate tax rates and more emphasis by the Treasury on taxing distributions to stockho...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
The difficulty of determining whether payments made by a corporation on its securities are dividends...
Federal income taxation of stock dividends has followed a diverse course. Since the introduction of ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
Allegations that stock dividends serve as a vehicle for deceptive financing, evasion of taxes, misle...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
In the case of Towne v. Eisner, the United States Supreme Court has recently held that under the Inc...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
The long awaited decision of the United States Supreme Court in Eisner v. Macomber (1920) 40 Sup. Ct...
The dividends paid deduction provided for in section 561 of the Internal Revenue Code is of vital im...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which ha...
With higher corporate tax rates and more emphasis by the Treasury on taxing distributions to stockho...
Under the Internal Revenue Code of 1954, the corporation is aseparate taxable entity, so that corpor...
P and B owned all the outstanding shares of X Corporation. In 1937 P purchased B\u27s shares and gav...
The difficulty of determining whether payments made by a corporation on its securities are dividends...