Add to ORKGThe Treasury\u27s recent amendment of its regulation regarding the treatment of purported debt obligations as a second class of stock for purposes of Subchapter S election represents a more defensible interpretation of the statute. However, since the regulation calls for an application of the principles of the thin incorporation doctrine to an area in which they are seemingly irrelevant, many Subchapter S corporations may be subjected to excessive penalties. This comment explores the decisional authority preceding the amendment, and examines the propriety of analyzing the one-class-of-stock requirement in terms of thin incorporation precepts
Although the device of incorporation has a number of advantages over other types of business organiz...
Plaintiffs owned 6 percent cumulative convertible prior preferred stock in defendant corporation. Th...
The coveted privilege of conducting business in the corporate form is not an unconditional grant.\u2...
The Treasury\u27s recent amendment of its regulation regarding the treatment of purported debt oblig...
There has been considerable controversy over interpretation of the requirement that there be only on...
Congress has substantially limited the use of Subchapter S corporations. To qualify as the requisite...
With higher corporate tax rates and more emphasis by the Treasury on taxing distributions to stockho...
Subject to a few exceptions, a corporation that has elected to be taxed under subchapter S of chapte...
The potentially advantageous treatment under subchapter S permitting certain corporations to elect t...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
The corporate form is often superior to other business structures because of the financial flexibili...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
The purpose of this brief note is to examine the provisions of section 1244 with a view toward quali...
The recent Louisiana case of State v. Stewart Brothers Cotton Co., lnc. raises the question of the t...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
Although the device of incorporation has a number of advantages over other types of business organiz...
Plaintiffs owned 6 percent cumulative convertible prior preferred stock in defendant corporation. Th...
The coveted privilege of conducting business in the corporate form is not an unconditional grant.\u2...
The Treasury\u27s recent amendment of its regulation regarding the treatment of purported debt oblig...
There has been considerable controversy over interpretation of the requirement that there be only on...
Congress has substantially limited the use of Subchapter S corporations. To qualify as the requisite...
With higher corporate tax rates and more emphasis by the Treasury on taxing distributions to stockho...
Subject to a few exceptions, a corporation that has elected to be taxed under subchapter S of chapte...
The potentially advantageous treatment under subchapter S permitting certain corporations to elect t...
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distri...
The corporate form is often superior to other business structures because of the financial flexibili...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
The purpose of this brief note is to examine the provisions of section 1244 with a view toward quali...
The recent Louisiana case of State v. Stewart Brothers Cotton Co., lnc. raises the question of the t...
In order to prevent the distribution of corporate income in the form of preferred stock which, upon ...
Although the device of incorporation has a number of advantages over other types of business organiz...
Plaintiffs owned 6 percent cumulative convertible prior preferred stock in defendant corporation. Th...
The coveted privilege of conducting business in the corporate form is not an unconditional grant.\u2...