Author: Calvin H. Johnson
Publisher:
ISBN:
Category :
Languages : en
Pages : 10
Book Description
In a transaction the IRS has called the midco shelter, a scoundrel evades tax on the sale of a corporation's business assets and shares the benefit of the evasion with the sellers of the corporation's stock and the buyers of its assets. Shareholders of a corporation with appreciated assets sell stock to the scoundrel, and the corporation sells its assets. Tax on the gain is due but the scoundrel evades tax. Asset buyers get a step-up in basis to cost without having to cover the tax on the asset sale. Stock sellers get a price greater than the net worth of assets, when tax due is considered.The proposal would make the selling shareholders secondarily liable for the corporate tax, limited by the premium they receive in excess of the corporation's net worth. That premium would be measured from the actual sales of corporate assets. The proposal would also make asset buyers secondarily liable for corporate tax, limited by the deemed value of the step-up in basis. The proposal would have no effect on current transferee liability law. The proposal is made as a part of the Shelf Project, a collaboration among tax professionals to develop proposals to help Congress raise revenue in ways that improve the fairness and efficiency of the tax system. Shelf projects follow the format of a committee report, describing current law and the reasons for change and providing an explanation of the proposal.
Profits from Tax Evasion Under the Midco Transaction
Author: Calvin H. Johnson
Publisher:
ISBN:
Category :
Languages : en
Pages : 10
Book Description
In a transaction the IRS has called the midco shelter, a scoundrel evades tax on the sale of a corporation's business assets and shares the benefit of the evasion with the sellers of the corporation's stock and the buyers of its assets. Shareholders of a corporation with appreciated assets sell stock to the scoundrel, and the corporation sells its assets. Tax on the gain is due but the scoundrel evades tax. Asset buyers get a step-up in basis to cost without having to cover the tax on the asset sale. Stock sellers get a price greater than the net worth of assets, when tax due is considered.The proposal would make the selling shareholders secondarily liable for the corporate tax, limited by the premium they receive in excess of the corporation's net worth. That premium would be measured from the actual sales of corporate assets. The proposal would also make asset buyers secondarily liable for corporate tax, limited by the deemed value of the step-up in basis. The proposal would have no effect on current transferee liability law. The proposal is made as a part of the Shelf Project, a collaboration among tax professionals to develop proposals to help Congress raise revenue in ways that improve the fairness and efficiency of the tax system. Shelf projects follow the format of a committee report, describing current law and the reasons for change and providing an explanation of the proposal.
Publisher:
ISBN:
Category :
Languages : en
Pages : 10
Book Description
In a transaction the IRS has called the midco shelter, a scoundrel evades tax on the sale of a corporation's business assets and shares the benefit of the evasion with the sellers of the corporation's stock and the buyers of its assets. Shareholders of a corporation with appreciated assets sell stock to the scoundrel, and the corporation sells its assets. Tax on the gain is due but the scoundrel evades tax. Asset buyers get a step-up in basis to cost without having to cover the tax on the asset sale. Stock sellers get a price greater than the net worth of assets, when tax due is considered.The proposal would make the selling shareholders secondarily liable for the corporate tax, limited by the premium they receive in excess of the corporation's net worth. That premium would be measured from the actual sales of corporate assets. The proposal would also make asset buyers secondarily liable for corporate tax, limited by the deemed value of the step-up in basis. The proposal would have no effect on current transferee liability law. The proposal is made as a part of the Shelf Project, a collaboration among tax professionals to develop proposals to help Congress raise revenue in ways that improve the fairness and efficiency of the tax system. Shelf projects follow the format of a committee report, describing current law and the reasons for change and providing an explanation of the proposal.
Description of Revenue Provisions Contained in the President's Fiscal Year ... Budget Proposal
Internal Revenue Cumulative Bulletin
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Tax administration and procedure
Languages : en
Pages : 1144
Book Description
Publisher:
ISBN:
Category : Tax administration and procedure
Languages : en
Pages : 1144
Book Description
Internal Revenue Bulletin
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 1930
Book Description
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 1930
Book Description
The Pin-Stripe Mafia
Author: Austin Vernon Mitchell
Publisher: Association for Accountancy &
ISBN: 9781902384122
Category : Accounting
Languages : en
Pages : 72
Book Description
Takes the lid off the corrupt practices of major accountancy firms that are impoverishing nations, undermining governments and condemning millions of people to misery.
Publisher: Association for Accountancy &
ISBN: 9781902384122
Category : Accounting
Languages : en
Pages : 72
Book Description
Takes the lid off the corrupt practices of major accountancy firms that are impoverishing nations, undermining governments and condemning millions of people to misery.
Tax Court Reporter: Current memo decisions
Author: Commerce Clearing House
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 2152
Book Description
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 2152
Book Description
United States Tax Reporter
Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures and Other Strategic Alliances, Financings, Reorganizations and Restructurings
Author:
Publisher:
ISBN:
Category : Consolidation and merger of corporations
Languages : en
Pages : 1312
Book Description
Publisher:
ISBN:
Category : Consolidation and merger of corporations
Languages : en
Pages : 1312
Book Description
Considering and Evaluating Airport Privatization
Author: Sheri Ernico
Publisher: Transportation Research Board
ISBN: 030921405X
Category : Aeronautics
Languages : en
Pages : 124
Book Description
TRB’s Airport Cooperative Research Program (ACRP) Report 66: Considering and Evaluating Airport Privatization addresses the potential advantages and disadvantages of implementing various approaches to airport privatization.
Publisher: Transportation Research Board
ISBN: 030921405X
Category : Aeronautics
Languages : en
Pages : 124
Book Description
TRB’s Airport Cooperative Research Program (ACRP) Report 66: Considering and Evaluating Airport Privatization addresses the potential advantages and disadvantages of implementing various approaches to airport privatization.