• Login
    View Item 
    •   Home
    • Yale Law School Faculty Scholarship
    • Faculty Scholarship Series
    • View Item
    •   Home
    • Yale Law School Faculty Scholarship
    • Faculty Scholarship Series
    • View Item
    JavaScript is disabled for your browser. Some features of this site may not work without it.

    Browse

    All of openYLSCommunitiesPublication DateAuthorsTitlesSubjectsThis CollectionPublication DateAuthorsTitlesSubjects

    My Account

    LoginRegister

    Statistics

    Display statistics

    Collapsible Corporations in a Nutshell

    • CSV
    • RefMan
    • EndNote
    • BibTex
    • RefWorks
    Thumbnail
    Name:
    Collapsible_Corporations_in_a_ ...
    Size:
    1.861Mb
    Format:
    PDF
    Download
    Author
    Bittker, Boris
    Eustice, James
    
    Metadata
    Show full item record
    URI
    http://hdl.handle.net/20.500.13051/1731
    Abstract
    Section 331(a) (1) of the Internal Revenue Code provides that a complete liquidation of a corporation is to be treated by a shareholder as a sale of his stock, and section 334(a) provides that a shareholder's basis for property acquired on a liquidation is its fair market value at the time of distribution. These long-established rules led to the tax avoidance device known as the "collapsible corporation" with which the Treasury Department has long been concerned. In 1950, Congress enacted a provision designed to deal with this form of tax avoidance, the predecessor of section 341 of the Internal Revenue Code of 1954. This article will examine the device known as the" collapsible corporation, " the manner in which section 341 has been used to prevent the conversion of ordinary income into capital gain, and the problems flowing from this provision.
    Collections
    Faculty Scholarship Series

    entitlement

     
    DSpace software (copyright © 2002 - 2023)  DuraSpace
    Quick Guide | Contact Us
    Open Repository is a service operated by 
    Atmire NV
     

    Export search results

    The export option will allow you to export the current search results of the entered query to a file. Different formats are available for download. To export the items, click on the button corresponding with the preferred download format.

    By default, clicking on the export buttons will result in a download of the allowed maximum amount of items.

    To select a subset of the search results, click "Selective Export" button and make a selection of the items you want to export. The amount of items that can be exported at once is similarly restricted as the full export.

    After making a selection, click one of the export format buttons. The amount of items that will be exported is indicated in the bubble next to export format.