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  • Bradley T. Borden

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Catalogue of legal authority addressing the federal definition of tax partnership

I. INTRODUCTION The following Table of Legal Authority Addressing the Federal Definition of Tax Partnership presents a summary of numerous statutes, cases, regulations, and rulings...

The Federal Definition of Tax Partnership

I. INTRODUCTION “When an entity must be classified for purposes of a Federal income tax statute, policy considerations of Federal income tax law should govern...

Taxing Shared Economies of Scale

ABSTRACT Economies of scale exist if long-run average costs decline as output rises. All else being equal, the decline in average costs should lead to...

Tax Opinions in TIC Offerings and Reverse TIC Exchanges

Co-author: Todd D. Keator[*] TABLE OF CONTENTS I.INTRODUCTION II.DEVIATIONS FROM THE REVENUE PROCEDURE A.Common Deviations 1.Deemed Consent 3.Investor Loans 4.Sponsor Guarantees 5.Sponsor Bridge Loans B.Significant Deviations...

Three Cheers for Passthrough Taxation

Table of Contents Cheer One: Technical Legitimacy Cheer Two: Horizontal Equity Cheer Three: Fairness Alternative Revenue-Generating Solution Conclusion Treasury Secretary Timothy Geithner recently suggested that...

Considering Tax Expenditures In State Budget Deliberations

I. Introduction I am going to speak generally about three components of state public finance: first, tax revenue; second, government expenditures; and third, the allocation...
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