P.O. Box 117625
Gainesville, FL 32611-7625
United States
University of Florida Levin College of Law
countryside, economic substance, tax avoidance, partnership, securities
economic substance, contingent liabilities, partnership, Cemco, Kornman, Stobie Creek, Jade, Sala, Klamath, retroactive, options, abuse, tax shelter, professional responsibility
carried interests, 710, H.R. 6275, H.R. 1935, H.R. 4213, deferred compensation, profits interest, compensatory partnership options, 83, 409A, 457A, distributions, hot assets, sales of partnership interests
partnership, profits interest, carried interest
Medicare Tax, Employment Taxes, Tax Reform, Tax Avoidance, Income Shifting, Partnerships, S Corporations, LLCs, Real Estate, Investment Managers, Trump Businesses, Renkemeyer
carried interests, proposed 710, H.R. 1935, deferred compensation, option equivalence, qualified capital exception, DRIP treatment, joint-tax perspective, 83 election
partnership, real estate, distribution, Countryside, basis, economic substance
tax reform,real estate partnerships
business tax reform, partnerships, capital gains, dividends, S corporations, compensation
partnership, nonrecourse, liability, Tufts, guarantee, LLC, limited liability, exculpatory, allocations
Corporate tax, Rangel, McCain, Obama, capital gains, dividends, integration, revenue, distributional, competitiveness, value added tax, economic distortions, expensing, territorial
estate tax, repeal, grass roots, polls, tax policy, political science
partnership, tax, LLC, liability, Hubert
tax shelter, economic substance, Stobie Creek, penalties, partnership, retroactivity, liabilities, contingent
partnership, options, services, capital shift, compensatory, noncompensatory
199A, passthrough deduction, choice of entity, employment taxes, 1411, TCJA, S corporations, partnerships
partnership, real estate, capital gain, sale of interest, redemption, basis adjustment, 751, 1(h)
tax, corporate tax, review, summary, federal income tax, corporations, tax reform, corporate tax reform, corporate reorganizations, NOLs, net operating losses, tax abuse, corporate tax abuse, tax avoidance, corporate tax avoidance, IPOs, mergers, tax history, corporate tax history, transactions
tax shelter, COBRA, Son-of-BOSS, arbitration, jurisdiction, fraud, professional responsibility, fee sharing, stock warrants, Carlisle, Curtis, Andersen, Bricolage, Clearmeadow, Tigers Eye, tax shelter promoter
partnership, basis adjustments, 704(c), intangibles, remedial
estate tax, corporate tax, dividends, budget, distributional effects, Bush tax cuts
Castle Harbour, tax shelter, substantiality, 704(c), 704(b), abuse, partnership, partners' interest, reallocation
carried interests, proposed 710, H.R. 1935, deferred compensation, profits interest, 83, 409A, 457A, qualified capital exception, ARSA options, DRIP treatment, joint-tax advantage, liquidation value
carried interests, 710, H.R. 1935, deferred compensation, management fee conversions, profits interests, section 707(a)(2)(A), section 83, guaranteed payments
tax, corporate tax, 2012, review, summary, federal income tax, corporations, tax reform, corporate tax reform, corporate reorganizations, consolidated returns, NOLs, net operating losses, start-ups, tax reporting, tax accounting, schedule UTP, corporate tax incidence, tax abuse, corporate tax abuse
partnership, limited, family, FLP, estate tax, gift tax, valuation, discount, marketability, control, retained interest, transfer tax
social security, privatization, investment, administrative, women, minorities, low income, budget
corporate tax
Medicare, employment tax, 1411, net investment income, partnerships, S corporations
partnership, 751, 734, 704(c), hot asset sale, Notice 2006-14, ordinary income, collapsible, basis adjustments, remedial allocations
tax policy, employee benefits
partnerships, 751(b), 743(b), basis adjustments, depreciation recapture
Partnership, Partner, Allocations, Equity, Culbertson, Castle Harbour, Classification, Business Purpose
Black & Decker, liability, contingent, tax shelter, purposive, statutory interpretation, Coltec
partnership, 704(c), 751, hot assets, ordinary income, basis adjustments, disproportionate, Notice 2006-14, collapsible
Hendler, liability, contingent, corporate, assumption, nonrecognition, tax shelter, Black & Decker, Coltec
pensions, social security, individual accounts, women, administrative, investment risk, default, 401(k), annuity
estate tax, repeal, carryover basis, budget, distributional, Bush tax cuts
Black & Decker, economic substance, liabilities, contingent, tax shelter, statutory interpretation, literalism
liabilities, nonrecourse, corporate, 357, 368, 362, assumption, tax shelter, stock basis
partnership, basis adjustments, 734, 743, tax shelter, loss duplication, inside basis, partial liquidation
Black & Decker, liability, contingent, textualism, literalism, statutory interpretation, economic substance, tax shelter
partnership, hot assets, 751, 704(c), allocations, Notice 2006-14
Camp proposals, partnerships, S corporations, employment taxes, 1374 tax, mandatory basis adjustments, corporate tax reform
corporate tax, partnerships, passthrough deduction, 199A, dividends, employment taxes
partnership, member, economic substance, check-the-box, Castle Harbour, Culbertson
partnerships, partners, guaranteed payments, 707
Castle Harbour, Bipartisan Budget Act of 2015, family partnerships, tax shelters
partnership, remedial allocations, partial liquidation, basis adjustments
partnership, foreign, intangibles, built-in gain
Woods, tax shelter, penalties, partnership
tax law, economic substance doctrine, transaction framing
