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Conflicting Definitions of "Liabilities" Threatens Some Tax-free Reorganizations

Show simple item record Phelan, Marilyn E. 2011-10-04T19:27:46Z 2011-10-04T19:27:46Z 1974
dc.identifier.citation 40 Journal of Taxation 345 en_US
dc.description.abstract The assumption of "liabilities" in reorganizations and Section 351 transfers can constitute boot and create taxable gain in an otherwise tax-free transaction. But what are "liabilities" for this purpose? Recent cases have raised conflicting theories about their nature (particularly for cash basis taxpayers), which can adversely affect a wide range of corporate transfers. Professor Phelan analyzes the impact of these late developments in the reorganization area.
dc.language.iso en_US en_US
dc.publisher Journal of Taxation
dc.subject Tax liabilities en_US
dc.subject Business reorganizations en_US
dc.subject Section 351 en_US
dc.subject Tax law en_US
dc.title Conflicting Definitions of "Liabilities" Threatens Some Tax-free Reorganizations en_US
dc.type Article en_US

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