Thin Capitalization

Front Cover
Ronald Press Company, 1958 - Close corporations - 261 pages
This book analyses the problem of the thin corporation - how to avoid tax traps without giving up the benefits. It considers validity of original capitalisation and recapitalisation, interest deduction, bad debt treatment, stepped-up basis for assets transferred to corporation, recognition of gain or loss on transfer, and stockholder guaranteed loans. The leading representative cases are analysed according to the pivotal factors involved, showing in each case the amount and ratio of debt to stock. The cases are further studied from the standpoint of the ratio test, valuation of underlying assets, business purpose, and the intent test.

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Contents

CHAPTER PAGE
19
THE Courts HAVE THE FINAL WORD
45
ANALYSIs of THE DEcisions
89
Copyright

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