Related corporations and triangular dividends: can the circle be squared?
Article Abstract:
Triangular dividends should be found for transactions between affiliated corporations when the primary motive for entering the transaction had no valid business purpose. Triangular dividends are a type of constructive dividend that can result in the taxation of the shareholders controlling the affiliated corporations. The IRS has failed to provide taxpayers with guidance on this doctrine, and it has taken the position that all transfers for less that adequate consideration result in constructive dividends.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
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The taxation of split-dollar life insurance: a solution to the dilemma
Article Abstract:
The continued uncertainty surrounding the income taxation of the equity build-up in split-dollar life insurance arrangements could be resolved by treating such policies like interest-free loans under IRC section 7872. Practitioners have found the IRS's use of section 83 to determine the taxation of split-dollar plans unsatisfactory. Use of section 7872 would better recognize the economic and tax principles implicit in the use of split-dollar arrangements.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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Stock redemptions, attribution rules and related parties: the tax maze for estates and trusts
Article Abstract:
In determining the tax liability of a corporation that redeems its stock, attribution rules are used to determine the stock's legal owner. These rules' applications to trusts and decedents' estates are examined.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2003
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- Abstracts: International accounting disharmony: the case of intangibles. Financial institutions, intangibles and corporate governance
- Abstracts: Contributions and co-ordination of individual fingers in multiple finger prehension. External finger forces in submaximal five-finger static pinch prehension
- Abstracts: Code Sec. 165(g): under the microscope. Corporate transactions and partnerships: an uneasy mix. Proposed revenue procedure may offer more opportunities for deferral for accrual method taxpayers