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
While the desire for limited liability has played its part in increasing the use of the corporate de...
The purpose of this brief note is to examine the provisions of section 1244 with a view toward quali...
While the desire for limited liability has played its part in increasing the use of the corporate de...
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...
The coveted privilege of conducting business in the corporate form is not an unconditional grant.\u2...
Subject to a few exceptions, a corporation that has elected to be taxed under subchapter S of chapte...
Senate Constitutional Amendment 5. Amends Section 3, Article XII, of Constitution. Declares constitu...
Plaintiffs, minority stockholders, sought to restrain the consummation of a merger agreement between...
This comment suggests the proper construction of Washington’s unlawful transactions provision of the...
In March 21, Congress codified a version of the economic substance doctrine, together with a stringe...
To combat a relatively arcane international tax-shelter abuse, Congress recently amended Code sectio...
Although the concepts of voting stock and voting power are pervasive throughout the Code, until ...
While the desire for limited liability has played its part in increasing the use of the corporate de...
The purpose of this brief note is to examine the provisions of section 1244 with a view toward quali...
While the desire for limited liability has played its part in increasing the use of the corporate de...
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...
The coveted privilege of conducting business in the corporate form is not an unconditional grant.\u2...
Subject to a few exceptions, a corporation that has elected to be taxed under subchapter S of chapte...
Senate Constitutional Amendment 5. Amends Section 3, Article XII, of Constitution. Declares constitu...
Plaintiffs, minority stockholders, sought to restrain the consummation of a merger agreement between...
This comment suggests the proper construction of Washington’s unlawful transactions provision of the...
In March 21, Congress codified a version of the economic substance doctrine, together with a stringe...
To combat a relatively arcane international tax-shelter abuse, Congress recently amended Code sectio...
Although the concepts of voting stock and voting power are pervasive throughout the Code, until ...
While the desire for limited liability has played its part in increasing the use of the corporate de...
The purpose of this brief note is to examine the provisions of section 1244 with a view toward quali...
While the desire for limited liability has played its part in increasing the use of the corporate de...