When a business that is a C corporation is sold, is it possible that related intangibles, including goodwill, can be considered to be owned by individual shareholders--and thus not subject to a corporate-level tax? In three recent cases, Kennedy v. Commissioner, n1 Howard v. United States, n2 and Muskat v. United States, n3 individual taxpayers took this position. In each case, the taxpayer was unsuccessful. But each of these cases recognizes that a shareholder-employee can individually own and sell intangible assets used in an incorporated business where the facts and circumstances support that position. This article discusses these three cases, as well as the development of the concept of personal goodwill and the stakes involved in being...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
There are many small corporations, the ownership o fwhich is in the hands of a family group or a few...
AbstractThe goodwill represents the future economic benefits arising from the assets that are not ca...
When a business that is a C corporation is sold, is it possible that related intangibles, including ...
Depending upon one\u27s particular circumstances, the vehicle of choice for a professional business ...
Use of a personal goodwill allocation in the sale of assets is the current darling of the tax wonk w...
Corporate acquisition talks may not get far if buyer and seller disagree over transaction structure,...
Plaintiffs were partners in a wholesale produce business which was well established and had a large ...
The nature of “goodwill” for tax purposes was an important issue in Australia long before the adopti...
The current rage in dispositional tax planning for closely-held C corporations is to bifurcate the s...
This article examines the tax opportunities and tax hazards when a subchapter S corporation makes a ...
This article examines the tax opportunities and tax hazards when a subchapter S corporation makes a ...
This comprehensive article analyzes the rules that apply to, and the tax planning strategies for, a ...
This comprehensive article analyzes the rules that apply to, and the tax planning strategies for, a ...
Transactions involving forgiveness by stockholder-employees of corporate indebtedness are shrouded i...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
There are many small corporations, the ownership o fwhich is in the hands of a family group or a few...
AbstractThe goodwill represents the future economic benefits arising from the assets that are not ca...
When a business that is a C corporation is sold, is it possible that related intangibles, including ...
Depending upon one\u27s particular circumstances, the vehicle of choice for a professional business ...
Use of a personal goodwill allocation in the sale of assets is the current darling of the tax wonk w...
Corporate acquisition talks may not get far if buyer and seller disagree over transaction structure,...
Plaintiffs were partners in a wholesale produce business which was well established and had a large ...
The nature of “goodwill” for tax purposes was an important issue in Australia long before the adopti...
The current rage in dispositional tax planning for closely-held C corporations is to bifurcate the s...
This article examines the tax opportunities and tax hazards when a subchapter S corporation makes a ...
This article examines the tax opportunities and tax hazards when a subchapter S corporation makes a ...
This comprehensive article analyzes the rules that apply to, and the tax planning strategies for, a ...
This comprehensive article analyzes the rules that apply to, and the tax planning strategies for, a ...
Transactions involving forgiveness by stockholder-employees of corporate indebtedness are shrouded i...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
There are many small corporations, the ownership o fwhich is in the hands of a family group or a few...
AbstractThe goodwill represents the future economic benefits arising from the assets that are not ca...