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
Corporate tax, Rangel, McCain, Obama, capital gains, dividends, integration, revenue, distributional, competitiveness, value added tax, economic distortions, expensing, territorial
partnership, real estate, distribution, Countryside, basis, economic substance
tax reform,real estate partnerships
partnership, nonrecourse, liability, Tufts, guarantee, LLC, limited liability, exculpatory, allocations
business tax reform, partnerships, capital gains, dividends, S corporations, compensation
partnership, tax, LLC, liability, Hubert
estate tax, repeal, grass roots, polls, tax policy, political science
partnership, options, services, capital shift, compensatory, noncompensatory
199A, passthrough deduction, choice of entity, employment taxes, 1411, TCJA, S corporations, partnerships
tax shelter, economic substance, Stobie Creek, penalties, partnership, retroactivity, liabilities, contingent
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, 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
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
corporate tax
partnerships, 751(b), 743(b), basis adjustments, depreciation recapture
partnership, real estate, capital gain, sale of interest, redemption, basis adjustment, 751, 1(h)
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
Castle Harbour, tax shelter, substantiality, 704(c), 704(b), abuse, partnership, partners' interest, reallocation
estate tax, corporate tax, dividends, budget, distributional effects, Bush tax cuts
partnership, basis adjustments, 704(c), intangibles, remedial
partnership, limited, family, FLP, estate tax, gift tax, valuation, discount, marketability, control, retained interest, transfer tax
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
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
social security, privatization, investment, administrative, women, minorities, low income, budget
tax policy, employee benefits
Partnership, Partner, Allocations, Equity, Culbertson, Castle Harbour, Classification, Business Purpose
Black & Decker, liability, contingent, tax shelter, purposive, statutory interpretation, Coltec
Hendler, liability, contingent, corporate, assumption, nonrecognition, tax shelter, Black & Decker, Coltec
partnerships, partners, guaranteed payments, 707
corporate tax, partnerships, passthrough deduction, 199A, dividends, employment taxes
pensions, social security, individual accounts, women, administrative, investment risk, default, 401(k), annuity
estate tax, repeal, carryover basis, budget, distributional, Bush tax cuts
partnership, 704(c), 751, hot assets, ordinary income, basis adjustments, disproportionate, Notice 2006-14, collapsible
partnership, remedial allocations, partial liquidation, basis adjustments
Black & Decker, economic substance, liabilities, contingent, tax shelter, statutory interpretation, literalism
liabilities, nonrecourse, corporate, 357, 368, 362, assumption, tax shelter, stock basis
partnership, hot assets, 751, 704(c), allocations, Notice 2006-14
Black & Decker, liability, contingent, textualism, literalism, statutory interpretation, economic substance, tax shelter
partnership, basis adjustments, 734, 743, tax shelter, loss duplication, inside basis, partial liquidation
partnership, member, economic substance, check-the-box, Castle Harbour, Culbertson
Camp proposals, partnerships, S corporations, employment taxes, 1374 tax, mandatory basis adjustments, corporate tax reform
partnership, foreign, intangibles, built-in gain
Castle Harbour, Bipartisan Budget Act of 2015, family partnerships, tax shelters
Woods, tax shelter, penalties, partnership
tax law, economic substance doctrine, transaction framing
State and local taxes, Notice 2020-75, Pass-through entity taxes, State tax credits, SALT cap
charitable deduction, state tax credits, SALT cap, passthrough loophole, §§ 162 164 and 170