To shut down a particular kind of offshore tax shelter scheme regarded as abusive, the Treasury has proposed changes in the way shareholders recover investment after engaging in corporate redemptions taxed as dividends. This article argues that the proposed regulations operate poorly in the more typical setting of distributions by corporations to individual shareholders, that existing law produces better results in those situations, and that the Treasury should employ narrower rules to attack tax shelter arrangements
Corporate law theory and practice considers shareholder relations with companies and the implication...
Since the repeal of the General Utilities doctrine over 30 years ago, corporations must recognize ga...
In this paper we explain why the current UK corporation tax discourages investment, consider how lar...
Coven asserts that one of the lingering ambiguities in subchapter C is how an appropriate tax benefi...
When a tax-exempt entity is both able and willing to lend its exemption to other taxpayers, tax-aver...
Inversion or expatriation transactions are often prompted by financial institutions, such as private...
Coven argues that the rules extending nonrecognition treatment to the incorporation of property neve...
This article discusses “inversion” transactions, in which a publicly traded U.S. corporation becomes...
Most previous legislative attacks on corporate tax shelters have targeted specific transactions and ...
Continued tax-motivated inversions of U.S. corporations into foreign corporations highlight the syst...
The debate rages on about how to tax private equity fund managers and hedge fund managers who, as pa...
This Article reviews the redemption provisions of both section 302 and section 304 of the Internal R...
This article describes the ongoing legislative and administrative efforts to curtail tax shelters. I...
A recent rise in the volume of corporate share repurchases has prompted calls for changes to the rul...
Educational endowments, private employer-sponsored pension plans, and other tax-exempt organizations...
Corporate law theory and practice considers shareholder relations with companies and the implication...
Since the repeal of the General Utilities doctrine over 30 years ago, corporations must recognize ga...
In this paper we explain why the current UK corporation tax discourages investment, consider how lar...
Coven asserts that one of the lingering ambiguities in subchapter C is how an appropriate tax benefi...
When a tax-exempt entity is both able and willing to lend its exemption to other taxpayers, tax-aver...
Inversion or expatriation transactions are often prompted by financial institutions, such as private...
Coven argues that the rules extending nonrecognition treatment to the incorporation of property neve...
This article discusses “inversion” transactions, in which a publicly traded U.S. corporation becomes...
Most previous legislative attacks on corporate tax shelters have targeted specific transactions and ...
Continued tax-motivated inversions of U.S. corporations into foreign corporations highlight the syst...
The debate rages on about how to tax private equity fund managers and hedge fund managers who, as pa...
This Article reviews the redemption provisions of both section 302 and section 304 of the Internal R...
This article describes the ongoing legislative and administrative efforts to curtail tax shelters. I...
A recent rise in the volume of corporate share repurchases has prompted calls for changes to the rul...
Educational endowments, private employer-sponsored pension plans, and other tax-exempt organizations...
Corporate law theory and practice considers shareholder relations with companies and the implication...
Since the repeal of the General Utilities doctrine over 30 years ago, corporations must recognize ga...
In this paper we explain why the current UK corporation tax discourages investment, consider how lar...