| dc.contributor.author |
Phelan, Marilyn E. |
|
| dc.date.accessioned |
2011-10-04T19:27:46Z |
|
| dc.date.available |
2011-10-04T19:27:46Z |
|
| dc.date.issued |
1974 |
|
| dc.identifier.citation |
40 Journal of Taxation 345 (1974) |
en_US |
| dc.identifier.uri |
http://hdl.handle.net/10601/1624 |
|
| 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.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 |