This Article begins by tracing the evolution of the accumulated earnings tax and the personal holding company tax from their origins to the mid-1980s. The Article then demonstrates the limited extent to which these corporate penalty taxes serve their historical purpose of preventing taxpayers from ...
Define subchapter. subchapter synonyms, subchapter pronunciation, subchapter translation, English dictionary definition of subchapter. n a chapter which is part of a larger chapter Collins English Dictionary – Complete and Unabridged, 12th Edition 2014
AnEINis a number that is used by the US Internal Revenue Service (IRS) to identify and tax businesses. It is essentially a Social Security number for a business. EINs are free when youapply directly with the IRS. Elect S Corp Tax Status ...
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...
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....
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 ...
Internal Revenue Code (IRC). Subchapter K covers the taxation of partners and partnerships and is said to be critical about substance and flexibility. It is said that Section 704 of the IRC is in crisis as more and more business entities are electing to be governed under Subchapter K. It ...
University of La Verne.Shiotsugu, Alice Amalia.University of La Verne.Shiotsugu, A.A. 2007. Complexity and Compliance of Partnership Taxation: A study of the Pass-Through Subchapter K Statute of the Internal Revenue Code, Dissertation, University of La Verne California....
This article focuses on tiered partnerships in relation to the internal revenue code, Subchapter K, and taxation in the U.S. For years now, taxpayers have used tiered partnership structures to accomplish a wide array of business objectives. They are used to segregate business assets and their ...
Planning for a QSSS. (qualified Internal Revenue Code Subchapter S subsidiaries)Huizenga, David L