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Keynote Address for Subchapter C Conference
The Political Environment of Corporate Tax Reform
6 other sections not shown
243 deduction 338 election acquired aggregate allocated American Law Institute amount apply asset basis attribution boot BROCKWAY buyer capital gain capital losses carryover basis election cash common stock complete liquidation Congress consolidated return continuity corporate level corporate tax corporate-level deferred discussion distribution double tax effect eliminated entity equity escrow exchange gain or loss GINSBURG golden parachute goodwill GU Repeal holders income tax installment method integration interest investment issue leveraged buyout leveraged recapitalization liabilities mark-to-market master limited partnerships Mgmt million NOLs notes option ordinary income ownership change paid parachute payment percentage preferred stock problem proposal purchase price qualify recapture recognize gain redemption regulations reorganization reporting revenue Reverse Subsidiary Merger rules section 338 securities sell shareholders shares small corporation step-up Subchapter substantially target corporation tax system tax-free taxable taxation taxpayer transaction transfer transferors treated treatment