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... of at least 10 percent of the partnership capital of a Partnership RBIC. However, neither a limited ... agreement between a RBIC and an Enterprise that obligates the RBIC to provide Financing (exce... officer or director (in the case of a corporation), or a manager (in the case of a limited liability...
... formulated in cases construing the Corporation Tax Act of 1909, the Court initially described inncome as the ''gain derived from capital, from labor, or from both combined,'' inclusive of... remained invested in the same general enterprise. Weiss v. Stearn, 265 U.S. 242 (1924), in which th...
Introduction. II. The Origins of SBE Theory in Louisiana and Its Detrimental Effects on Business Policy. A. Green v. Champion Insurance Co. and the Origins of SBE. B. Criticism of Single Business Enterprise Theory and the Eighteen Factor Test. 1. SBE: A FlawedLegal Framework. a. Factors Present in Nearly All Parent-Subsidiary Structures. b. Inconsistent Factors. 2. SBE: A Poor Policy Choice for Louisiana. a. SBE Theory Ignores Traditional Veil-Piercing Jurisprudence. b. SBE Theory Ignores the Myriad of Legitimate Reasons for a Multiple-Entity Corporate Structure. c. SBE Theory Discourages the Investment of Capital and Increases the Cost of Doing Business. d. SBE Theory Can Produce Adverse and Unintended Effects for Creditors. e. SBE Theory Poses a Serious Threat to Contractual Relati...
... grant of limited liability to corporations and limited liability companies. This in turn coul...
Although a $25 million venture capital program set up by the Legislature nine years ago at the request of then-Gov. Bob Wise has lost $20.8 million, there is no way for taxpayers to know any details about profits and losses. At the Legislature's direction, $25 million was taken from general revenue and the state Economic Development Authority created the West Virginia Enterprise Advancement Corp. to run the program. The authority and the advancement corporation have identical directors and staff.
... closely held or controlled foreign corporations deriving principally passive or related-party inco... foreign corporation's ordinary income to capital gains subject to preferential tax rates. Congress ... low income or losses from the active enterprise may nonetheless generate enough passive income (su...
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