Reinstating Code Sec. 6166 eligibility after the Taxpayer Relief Act of 1997

Article Abstract:

Congress provided a partial solution in the Taxpayer Relief Act of 1997 to the problem of estates denied relief under IRC section 6166 with new section 7479. Section 6166 allows deferrals of payments of estate taxes by qualifying closely-held businesses and is a section which the IRS has historically limited. Section 7479 allows taxpayers who have exhausted IRS administrative remedies to seek declaratory relief from the Tax Court stating that they are entitled to section 6166 benefits.

Laws, regulations and rules, Interest deductions, Estate tax, Estate taxes, Judgments, Declaratory, Declaratory judgments

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Do we really need nonqualified preferred stock? A rethinking of the taxation of corporate capital

Article Abstract:

The tax treatment of all forms of corporate capital should be uniform to eliminate the manipulation of Tax Code provisions to minimize taxation. Distinctions between capital structure according to preferred and common stock or debt and equity allow tax planning to result in congressionally unintended government revenue loss. A neutral system of taxing financial instruments should be based upon a general principle of either recognition or nonrecognition of gain.

Tax Law, Public Finance Activities, Tax Management, Analysis, Taxation, Tax accounting, Corporations, Securities, Financial instruments, Tax policy, Capital

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Monitoring remuneration of outside corporate directors

Article Abstract:

The author discusses the monitoring needs for remuneration to outside directors who serve on corporate compensation committees in order to avoid disqualification.

Planning, Corporate directors, Compensation and benefits, Compensation management

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