Walter D. Schwidetzky

University of Baltimore - School of Law

Professor

1420 N. Charles Street

Baltimore, MD 21218

United States

SCHOLARLY PAPERS

18

DOWNLOADS
Rank 33,360

SSRN RANKINGS

Top 33,360

in Total Papers Downloads

3,299

TOTAL CITATIONS

4

Scholarly Papers (18)

1.

Integrating Subchapters K and S-Just Do it

Tax Lawyer, Vol. 62, No. 3, p. 749, 2009, University of Baltimore School of Law Legal Studies Research Paper No. 2010-04
Number of pages: 75 Posted: 01 Oct 2009 Last Revised: 03 Mar 2010
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 1,155 (40,548)
Citation 2

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business entities, Subchaper K, Subchapter S, partnerships, S corporations, taxation, LLC's, limited liability companies, closely held businesses, H.R. 4137

2.

The Partnership Allocation Rules of Section 704(b): To Be or Not to Be

Virginia Tax Review, Vol. 17, No. 4, 1998
Number of pages: 52 Posted: 16 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 936 (54,544)

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partnership allocation regulations, substantial economic effect rules, nonrecourse deductions rules, Crane v. Commissioner, taxation

3.

Family Limited Partnerships: The Beat Goes On

Tax Lawyer, Vol. 60, p. 277, 2007
Number of pages: 65 Posted: 03 Sep 2008 Last Revised: 27 Jan 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 214 (307,170)
Citation 1

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family limitied liability entities, FLLEs, limited partnerships, limited liability companies, estate taxes, gift taxes, Internal Revenue Code, taxation

4.

A Comparison of Corporate Taxation in the United States and Germany: Different Ways Up the Mountain

Georgia Journal of International and Comparative Law, Vol. 28, P. 217, 2000
Number of pages: 31 Posted: 17 Oct 2000 Last Revised: 13 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 171 (377,300)

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United States, Germany, taxation, corporations, financial accounting rules, taxation of dividends, capital gains, capital losses, liquidations, reorganizations

5.

Options to Acquire Partnership Interests: Can the Tax Law Keep Pace?

Journal Taxation of Investments, Vol. 20, No. 2, 2003
Number of pages: 23 Posted: 16 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 128 (479,419)

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partnerships, options, federal tax treatment, IRS, Internal Revenue Service, services option, limited liability companies

6.

Is it Time to Give the S Corporation a Proper Burial?

Virginia Tax Review, Vol. 15, No. 4, 1996
Number of pages: 61 Posted: 18 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 113 (527,592)

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S Corporations, small businesses, limited liability company, LLC, limited liability partnership, LLP

7.

Partnership Taxation: Restructuring Partnership Debt - Life is Change

Virginia Tax Review, Vol. 11, No. 3, 1992
Number of pages: 56 Posted: 22 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 112 (531,177)

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partnership debt, partnership taxation, U.S. v. Kirby Lumber, Bankruptcy Tax Act of 1980, COD, partnership insolvency

8.

Last-Gasp Estate Planning: The Formation of Family Limited Liability Entities Shortly Before Death

Virginia Tax Review, Vol. 21, No. 1, 2001
Number of pages: 41 Posted: 16 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 109 (541,885)

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family limited partnerships, estate tax planning, LLCs, limited liability companies, family limited liability entity, FLLE, Strangi

9.

The New Activity Regulations Under Section 469: Into the Abyss

Virginia Tax Review, Vol. 9, No. 3, 1990
Number of pages: 71 Posted: 24 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 65 (743,279)

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Tax Reform Act of 1986, passive loss rules, passive income, legislative history, taxation, IRS, Internal Revenue Service

10.

In Defense of the PIP Regulations

72 The Tax Lawyer 519 (2019), University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 32 Posted: 12 Feb 2020
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 61 (768,323)

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Fair market value; Case law; Taxation; Stockholders; Partnership agreements; Partnership interest; Tax basis; Limited partnerships; S corporations; Pass through entities

11.

Hyperlexis and the Loophole

Oklahoma Law Review, Vol. 49, No. 3, Fall 1996, pp. 403-424
Number of pages: 22 Posted: 01 Oct 2014
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 51 (839,265)
Citation 1

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hyperlexis, Congress, tax law, Internal Revenue Code, partnership taxation, subchapter K, loopholes, value added tax

12.

Temporary and Proposed Section 752 Regulations: Progress or Regress?

35 Journal of Taxation of Investments 3 (2017), University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 39 Posted: 12 Feb 2020
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 50 (847,045)

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bottom-dollar guarantee, economic risk of loss, recourse debt, commercially reasonable, anti-abuse regulation

13.

Proposed Regulations on Noncompensatory Options: A Light at the End of the Tunnel

Journal of Taxation of Investments, Vol. 21, No. 2, Winter 2004
Number of pages: 32 Posted: 29 Jun 2004 Last Revised: 13 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 48 (863,145)

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partnerships, noncompensatory options, services options, regulations, taxation

14.

Complexity Cubed: Partnerships, Interest, and the Proposed Regulations

Tax Notes Federal, November 18, 2019, University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 98 Posted: 12 Feb 2020
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 45 (888,368)

Abstract:

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business interest expenses, section 163(j), partnerships

15.

Estate Planning: Hyperlexis and the Annual Exclusion Rule

Suffolk University Law Review, Vol. 32, No. 2, 1998, pp. 211-232
Number of pages: 22 Posted: 01 Oct 2014
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 41 (924,486)

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Internal Revenue Code, I.R.C. § 2503(b), gift tax, gifts, taxpayers, simplification, hyperlexis, Bayless Manning, federal legislatures, state legislatures, complexity

16.

The Wyden Proposals on Partnership Debt: Step Forward or Back?

76 Tax Lawyer 389 (2023) , University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Posted: 21 Jun 2023
Walter D. Schwidetzky
University of Baltimore - School of Law

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Section 752, partnership debt, economic risk of loss, recourse debt, nonrecourse debt, profit shares

17.

Complexity Cubed: Partnerships, Interest Expenses, and the Proposed Regulations

165 Tax Notes 1113 (2019)
Posted: 21 Jun 2023
Walter D. Schwidetzky
University of Baltimore - School of Law

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18.

Partnership Debt Workouts During a Pandemic

169 Tax Notes 229 (2020)
Posted: 14 Jun 2023
Walter D. Schwidetzky
University of Baltimore - School of Law

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partnerships, CODI, Garcia, modification of debt instruments, OID, squeeze downs