Examines the anachronisms in Subchapter K provision of the Internal Revenue Code section 736 in the U.S. enacted to settle tax treatment of payments by a partnership to a retiring partner or to a successor. Information on the structure and operation of the Subchapter K provision; Influence of...
Internal Revenue Code of 1986 SUBTITLE F -- PROCEDURE AND ADMINISTRATION Chapter 66 -- Limitations Subchapter B -- Limitations on Credit and Refund (a)Period of limitation on filing claim. Claim for credit or refund of an overpayment of any tax imposed by this title in respect of which tax...
(iii)REITyear.Forpurposesofthissubparagraph,theterm"REITyear"meansanytaxableyearforwhichtheprovisionsofpartIIofsubchapterM(relatingtorealestateinvestmenttrusts)applytothetaxpayer.(C)Specifiedliabilitylosses.Inthecaseofataxpayerwhichhasaspecifiedliabilityloss(asdefinedinsubsection(f))forataxableyear,suchspecified...
ByLarry Branton7.17.24Posted inInternal Revenue Code,Tax Laws,Tax Planning Unlike the rules contained in Subchapter K surrounding partnership distributions, which tend to be somewhat complex, the distribution rules contained in Subchapter S are fairly straightforward. Nevertheless, from time to time, ta...
(3)subparagraph (B) of section 1030(a)(2) of title 18, United States Code, the Secretary shall notify such taxpayer as soon as practicable of such inspection or disclosure. The Secretary shall also notify such taxpayer if the Internal Revenue Service or a Federal or State agency (upon not...
Anachronisms in Subchapter K of the Internal Revenue Code: Is It Time to Part with Section 736?Brutus: Peace! Count the clock. Cassius: The clock hath stricken three. Trebonius: 'Tis time to...Postlewaite, Philip F.Rosenzweig, Adam H....
Jeffrey L. KwallSocial ence Electronic Publishing
was quickly repudiated by the Revenue Act of 1924,' but in 19348 the still more drastic technique of treating all liquidating gains as short-term capital gains was adopted. In the field of complete liquidations this lasted only until the Revenue Act of 1936;' but, because of the supposed ...
The brand new world of S corporation reorganizations. (Internal Revenue Code Subchapter S)Karlinsky, Stewart S
Purpose. The purpose of this study was to investigate a specific federal taxation policy provision of the United States Internal Revenue Tax Code, the Partnership Taxation statute known as Subchapter K. In addition, the researcher sought to determine any associative or causal relationship between ...