Vol. 67, No. 2 - Winter 2014

Taxation

When Subchapter S Meets Subchapter C

Martin J. McMahon, Jr., and Daniel L. Simmons

It is often said that “an S corporation is a corporation that is taxed like a partnership.” This statement is incorrect. An S corporation resembles a partnership only in that it generally does not pay income taxes...

Taxation

The First National Income Tax, 1861–1872

Sheldon D. Pollack

During the first months of the American Civil War, an important political debate played out in the U.S. Congress over how to restructure the nation’s system of public finance and taxation. ...

Options for Tax Reform in the Inbound International Tax Provisions of the Internal Revenue Code

ABA Section of Taxation

These options for tax reform (Options) were submitted on behalf of the American Bar Association Section of Taxation to the Senate Finance and House Ways and Means Committees on December 3, 2013. ...

Taxation

Lightened Taxpayer Burdens in the Sale of Personal Goodwill After H&M, Inc. v. Commissioner

Mona Shin

In any negotiation for the purchase of a business, the valuation of the various assets of the business is likely to be a contentious issue. Valuation is challenging not only because the purchase price of the business...

Taxation

I Am the Master(s) of My Fate: Owen v. Commissioner and the Assignment of Income Doctrine in the Context of Personal Service Corporations

Robert D. Stewart

Despite the Supreme Court holding in 1930 that earned income is presumptively taxable to the person who actually earns the income, determining who actually earned the income...