Journal of Corporate Taxation 1993 - Abstracts

Journal of Corporate Taxation 1993
Ability to have a triangular acquisition is restricted. (I.R.S. Technical Advice Memorandum 9215005)LawBloom, Gilbert D.
Are expenses incurred in obtaining LBO loans deductible? (leveraged buyout)LawBernstein, Robert S., Akselrad, Ira
Bank holding company/bank combinations. (I.R.S. Private Letter Ruling 9240026)LawBloom, Gilbert D.
Capital assets: the inventory exception to Section 1221 revisited. (I.R.C.)LawSeetharaman, Ananth
Clearing the deck of Waterman Steamship: pre-reorganization dividends and assumption of shareholder debt. (corporate stock reorganizations and Commissioner v. Waterman S.S. Corp.)LawRizzi, Robert A.
Decoding the uniform capitalization regulations applicable to manufacturers.LawKeeling, Kermit O., Sedaghat, Ali M.
Deemed dividends in cross-border Section 304 transactions. (dividend payments by a domestic corporation to a foreign corporation taxable under I.R.C. Section 304)LawEngle, Howard S.
Dual consolidated loss rules - final regulations. (losses of dual resident companies)LawEngle, Howard S.
Elective retroactive use of the Section 367 regulations. (I.R.S. Private Letter Ruling 9218062 on I.R.C. Section 367)LawBloom, Gilbert D.
Exclusions from income for qualified individuals employed outside the United States.LawBudinger, Sandhya C.
Extension of U.S. stock plans to nonresident aliens.LawNavin, Patrick T.
Final Regulations under Section 512 - swap income and tax-qualified pension plans. (I.R.C.)LawEllis, David W.
Foreign tax credit limitation rules.LawEngle, Howard S.
Front-end realignments: non-pro rata contributions of stock before corporate acquisitions.LawRizzi, Robert A.
Liquidation coupled with some reincorporation. (I.R.S. Private Letter Ruling 9210041)LawBloom, Gilbert D.
Liquidation distributions: the decision to utilize Section 453(h).LawWhite, Stephen J., Pratt, James W.
New proposed regulations limit the deemed exercise rule for options under Section 382. (I.R.C. Section 382 and loss corporation stock)LawBernstein, Robert S., Akselrad, Ira
New rules concerning limitations on U.S. tax benefits from operations in restricted countries. (I.R.S. Revenue Rulings 92-62 and 92-63)LawEngle, Howard S.
Nontaxable purchase-price reduction versus taxable disposition - the interplay between Sections 108(e)(5) and 453B(f). (I.R.C.)LawOrefice, James A.
Proposed regulations apply section 163(j) to consolidated returns and other affiliated groups.LawFerencz, Glenn E.
Quantity and quality in the substantially all requirement. (C, G and triangular corporate reorganizations)LawRizzi, Robert A.
Retirement plan investments in company stock.LawMcBreen, Maura Ann
Service asserts continued vitality of old Revenue Ruling but will not penalize consistent good-faith contrary positions. (I.R.S. Revenue Ruling 57-7)LawFriedrich, Craig W.
Sidestepping the business purpose test for corporate spin-offs.LawAgar, Raymond S., Tracy, Michael P.
Spin-off of newly formed subsidiary results in recapture of ITC. (investment tax credit and Salomon, Inc. v. U.S.)LawFriedrich, Craig W.
Stock acquisitions and liquidations by S corporations: availability of benefits afforded by sections 332 and 338.LawZachary, Seth M., Weingold, Philip R.
Stock swap permitted? (I.R.S. Private Letter Ruling 9224016)LawBloom, Gilbert D.
Taxation of foreign dividends. (Kraft Foods v. Iowa Department of Revenue)LawEngle, Howard S.
The brave new world of consolidated returns: an analysis of the recently proposed stock basis adjustment regulations.LawCollins, Bryan P., Nissley, P. Anthony, Morzorati, Lynn M., Tiedmann, William J.
The proposed Section 338 regulations: some good news from General Utilities repeal. (I.R.C.)LawBridgeman, James D.
The tax-free entity under the U.S. flag: a U.S. Virgin Islands exempt company.LawBlum, William L.
The Treasury's debt modification regulations: Cottage Savings proves a perilous beacon. (Cottage Savings v. Commissioner)LawFriedrich, Craig W.
To B or not to B: distinctions between B and reverse triangular reorganizations defy logic but provide flexibility in restructuring. (corporate reorganizations)LawRizzi, Robert A.
Transfer pricing: the new Section 482 temporary and proposed regulations.LawEngle, Howard S.
United States tax considerations in organizing a foreign joint venture.LawParnes, Alan P.
What constitutes a change in accounting method: is it merely a timing question?LawHorvitz, Jerome S., Linton, Frank B.
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