corporation taxation

• 26 CFR 1.991-1 - Taxation of a domestic international sales corporation.

• Code of Federal Regulations - Title 26: Internal Revenue

• Llcs Are the New King of the Hill: An Empirical Study of the Number of New Llcs, Corporations, and Lps Formed in the United States Between 2004-2007 and How Llcs Were Taxed for Tax Years 2002-2006

A revolution has occurred in the world of business organizations law. The limited liability company (LLC) is now undeniably the most popular form of new business entity in the US. This is amazing, especially because for most of America's history the general partnership and the corporation dominated the business organizations' landscape. Further, there is no other alternative entity on the horizon that shows the promise or potential to unseat the LLC as the new king of the hill. The only areas that have not been dominated by the LLC are those of publicly traded companies, companies that plan to become publicly traded companies, and non-profit entities. Commentators should explore the relative risks and benefits of structuring an LLC to be taxed as an S-Corporation as opposed to simply us...

...(2) to report data demonstrating that the taxation of LLCs is quickly becoming more varied than most ...

• Fordham Journal of Corporate & Financial Law
• Vol. 15 Nbr. 2, January 2010

• Current developments.

Part 1 - In S Corporation taxation issues

• The Tax Adviser
• Vol. 34 Nbr. 10, October 2003

• Louisiana Revised Statutes Section 47:201.1 and the Taxation of Nonresident Partners: An Alternate Proposal

The Need For Section 47:201.1: Jurisdiction To Tax II. Revised Statutes Section 47:201.1 III. Problems Under Section 47:201.1 IV. Louisiana Taxation of S Corporation Income V. The Only-One-Class-of-Stock Requirement VI. Economic Considerations VII. Proposed Legislation VIII. Conclusion

• Louisiana Law Review
• Nbr. 61-4, July 2001

• 15 USC 713 - Sec. 713a-5. Exemption of Commodity Credit Corporation and its obligations from taxation

• U.S. Code - Title 15: Commerce and Trade

• Different redemption rights did not create second class of stock.

In S corporation taxation

• The Tax Adviser
• Vol. 35 Nbr. 2, February 2004

• James W. Wetzler, as Commissioner of Taxation and Finance of the State of New York, and the New York State Department of Taxation and Finance, Plaintiffs-Appellants, v. Federal Deposit Insurance Corporation, as Receiver of the Seamen'S Bank for Savings, F.S.B., Defendant-Appellee. Federal Deposit Insurance Corporation, Counter-Claimant, v. James W. Wetzler and New York State Department of Taxation and Finance, Counter-Defendants., 38 F.3d 69 (2nd Cir. 1994)

Frederic L. Lieberman, Asst. Atty. Gen. of the State of N.Y., New York City (G. Oliver Koppell, Atty. Gen. of the State of N.Y., of counsel), for plai...

• Federal Circuits

• Current developments.

Part 1 - Developments in S corporation taxation in switching from accural to cash method accounting

• The Tax Adviser
• Vol. 33 Nbr. 10, October 2002

• PFIC/CFC overlap: not out of the woods yet.

Passive foreign investment company/controlled foreign corporation taxation

• The Tax Adviser
• Vol. 34 Nbr. 6, June 2003

• International Tax Experts Examine the Taxation of Multinational Corporation Loan Guarantees in Bna Webinar Following Uk Summit

ARLINGTON, Va., Oct. 7 /PRNewswire-USNewswire/ -- At a time when lending institutions are naturally risk-averse, multinational corporations increasingly find themselves providing guarantees to enable group members to obtain loans on satisfactory terms. Where a cross-border element is involved, analyzing the potential tax consequences can be complex and subject to a degree of uncertainty. The tax treatment of loan guarantee fees has been receiving a lot of attention lately, particularly in light of the GE Capital case in Canada, the Container Corp. case in the U.S. and the September 27 law effectively overturning the decision in the latter case. (Logo: http://photos.prnewswire.com/prnh/20090114/DC59060LOGO-b)

• U.S. Newswire
• October 07, 2010