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- Title
FIFTEEN AND THIRTY-FIVE CLASS WARFARE IN SUBCHAPTER K OF THE INTERNAL REVENUE CODE: THE TAXATION OF HUMAN CAPITAL UPON THE RECEIPT OF A PROPRIETARY INTEREST IN A BUSINESS ENTERPRISE.
- Authors
Postlewaite, Philip F.
- Abstract
The article focuses on the compensatory equity transfer and its similarities and dissimilarities which include those arising in the corporate setting in the U.S. It mentions that the erroneous assumption that profits interests results in unique and unfair tax treatment. It mentions that focusing on one of the five traditional types of available equity transfers confuses academic commentary on the need for tax reform.
- Subjects
UNITED States; CORPORATE profits; TAX reform; TAXATION of corporate profits; TAXATION of stock transfers; TAXATION of business enterprises; INTERNAL revenue
- Publication
Virginia Tax Review, 2009, Vol 28, Issue 4, p817
- ISSN
0735-9004
- Publication type
Article