PARTNERSHIP TAX PLANNING: NAVIGATING THE CANAL.

Autor: RUBIN, BLAKE D., WHITEWAY, ANDREA MACINTOSH, FINKELSTEIN, JON G.
Zdroj: Practical Tax Strategies; May2013, Vol. 90 Issue 5, p196-210, 15p
Abstrakt: The article explores the partnership sale transaction of Canal Corporation which was formerly known as Chesapeake Corporation. After WISCO declared a dividend of 166 million U.S. dollars to Chesapeake in 2001, the U.S. Internal Revenue Service (IRS) issued a deficiency notice for 1999 to Chesapeake as the transaction constituted a disguised sale of assets. Judge Kroupa of the Tax Court ruled that the transaction failed to meet the exception of partnership disguised sale treatment.
Databáze: Supplemental Index