Section 678Grantor TrustIncome TaxThis article explores Section 678 of the Internal Revenue Code and how and when a beneficiary is deemed to be the owner of a trust for income tax purposes (calldoi:10.2139/ssrn.3165592Morrow, Edwin PSocial Science Electronic Publishing...
If the allowance of an application, credit, or refund of a decrease in tax determined under section 6411(b) is otherwise prevented by the operation of any law or rule of law other than section 7122, such application, credit, or refund may be allowed or made if application for a tentative...
IMPLICATIONS OF THE CONCEPT OF ENACTED ENVIRONMENT FOR STRATEGIC MANAGEMENT 1)Abandoning the prescription that organizations should adapt to their environments 2)Rethinking constraints, threats and opportunities 3)Considering the primary role of the strategic managers to be the management of meaning MANAGING...
This can be an issue. Take a look at IRC::Utils' section on it.BUGSA few have turned up in the past and they are sure to again. Please use http://rt.cpan.org/ to report any. Alternatively, email the current maintainer.DEVELOPMENTYou can find the latest source on github: http://...
IRC Section 409(p) and S Corporation ESOPsBrian D. HectorJason C. Ray
In this paper, we discuss the legislative history of Code Section 6103 and its precursors which provide for disclosure of tax returns to shareholders who own more than one percent of the capital stock. We then provide examples of the valuable proprietary information that is included in corporate ...
IRC Section 1031 Tax-Deferred ExchangesInternational Red CrossTax-deferred ExchangesAbilitiesTaxesGainsIntermediariesSellersReplacementUsing Tenancy-in-Common Interests as Replacement PropertyMaples, LarryCaldwell, Charles WWood, Bob G., J...
See eg Harold Dubroff & Douglas A Kahn, Federal Taxation of Estates, Gifts, and Trusts(3d ed, Foundation Press: Westbury, NY, 1980)2 3. 3 Robert Lenzer and Philippe Mao, 'TheKinsler, Jeffrey S
Findings – The results show that the presence of CEO duality does not influence the likelihood of permitting a Section 83(b) election. However, the tenure of the CEO significantly increases the likelihood of permitting a Section 83(b) election. Research limitations/implications – This study is...
Section 355: corporate spinoffs. - e - IRC section 355e