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Author: Theodore D. Peyser Publisher: ISBN: 9781558716827 Category : Inheritance and transfer tax Languages : en Pages :
Book Description
... Analyzes the rules of [section] 6901 and related judicial interpretations. Beginning with a general discussion of transferee liability and its development from the so-called trust fund doctrine, the Portfolio distinguishes between transferee liability in equity and liability at law. The liability of a transferee at law or equity for the tax of the transferor is governed by state law and in some cases by federal statutes. The liability of the transferor is determined under the Internal Revenue Code. Section 6901 does not create a separate liability for the transferee; instead, it provides a regime to facilitate collection by the IRS from a third party of the tax due from the transferor and to permit the third party/transferee to contest the IRS determination in the U.S. Tax Court. The Portfolio also discusses the liability of a fiduciary under 31 U.S.C. [section] 3713(b) and the application of [section] 6901 to this type of liability.
Author: Theodore D. Peyser Publisher: ISBN: 9781558716827 Category : Inheritance and transfer tax Languages : en Pages :
Book Description
... Analyzes the rules of [section] 6901 and related judicial interpretations. Beginning with a general discussion of transferee liability and its development from the so-called trust fund doctrine, the Portfolio distinguishes between transferee liability in equity and liability at law. The liability of a transferee at law or equity for the tax of the transferor is governed by state law and in some cases by federal statutes. The liability of the transferor is determined under the Internal Revenue Code. Section 6901 does not create a separate liability for the transferee; instead, it provides a regime to facilitate collection by the IRS from a third party of the tax due from the transferor and to permit the third party/transferee to contest the IRS determination in the U.S. Tax Court. The Portfolio also discusses the liability of a fiduciary under 31 U.S.C. [section] 3713(b) and the application of [section] 6901 to this type of liability.
Author: Ellen S. Brody Publisher: ISBN: 9781633591745 Category : Inheritance and transfer tax Languages : en Pages :
Book Description
" ... analyzes the rules of [section] 6901 and related judicial interpretations. Beginning with a general discussion of transferee liability and its development from the so-called trust fund doctrine, the Portfolio distinguishes between transferee liability in equity and liability at law. The liability of a transferee at law or equity for the tax of the transferor is governed by state law and in some cases by federal statutes. The liability of the transferor is determined under the Internal Revenue Code. Section 6901 does not create a separate liability for the transferee; instead, it provides a regime to facilitate collection by the IRS from a third party of the tax due from the transferor and to permit the third party/transferee to contest the IRS determination in the U.S. Tax Court. The Portfolio also discusses the liability of a fiduciary under 31 U.S.C. [section] 3713(b) and the application of [section] 6901 to this type of liability"--P. (iii).
Author: Bradley T. Borden Publisher: Wolters Kluwer ISBN: 1454820209 Category : Languages : en Pages : 20092
Book Description
The foremost authority on state laws governing limited liability companies, limited partnerships, and limited liability partnerships. This resource covers choice of entity, formation, admission, dissociation, dissolution, wind up, tax treatment; statutory and case sources are brought together in an accessible manner. By Bradley T. Borden, Robert J. Rhee Limited Liability Entities: State by State Guide to LLCs, LPs and LLPs is the country's foremost authority on the state laws governing limited liability companies, limited partnerships, and limited liability partnerships. It contains expert analysis and commentary by two of the nation's most renowned experts in this area of the law and compiles statutory and case sources in an accessible manner. Authors Bradley Borden and Robert Rhee provide seven annual updates to this product, making it the most timely and comprehensive work of its kind. Volume 1 provides a comprehensive overview of limited liability entities. It begins with a detailed review of the history and evolution of limited liability entities. It then provides an in-depth examination of the general state-law principles that govern limited liability entities, using the uniform limited liability entity laws as a basis for the discussion. Volume 1 also provides comprehensive coverage of the tax treatment of limited liability entities. Starting with Volume 2, the treatise provides in-depth coverage of the respective state laws that govern limited liability entities. For each state, the treatise provides commentary about the state law, including discussion of relevant case rulings. In these commentaries and when appropriate, comparisons are made to other state law and the uniform laws. These volumes also reproduce the relevant state laws that govern limited liability entities. Volume 2 covers the states of Alabama through Colorado Volume 3 covers the states of Connecticut through Hawaii Volume 4 covers the states of Idaho through Kentucky Volume 5 covers the states of Louisiana through Minnesota Volume 6 covers the states of Mississippi through New Hampshire Volume 7 covers the states of New Jersey through Ohio Volume 8 covers the states of Oklahoma through South Dakota Volume 9 covers the states of Tennessee through Vermont Volume 10 covers the states of Virginia through Wyoming
Author: Jens Kirchner Publisher: Springer ISBN: 3662490072 Category : Law Languages : en Pages : 745
Book Description
This book provides practical, business-orientated and accessible guidance on key employment and labour law aspects in national and international transfers of business in the European Union, its member states and selected important countries around the world. It contains a comprehensive overview of relevant topics such as safeguarding of employees' rights, impacts on employees' representatives and on collective agreements, company pension entitlements, insolvency, M&A transactions and cross-border transfers of business for each country covered. This overview is accompanied by summaries of leading case law and excerpts of important national regulations. Transfers of business play an important role in today's globalised business world. In particular, employment and labour impacts of transfers of businesses are often a driving legal and business factor in national and international restructurings and M&A transactions. The successful implementation of transfers of business requires to recognise and comply with the relevant legal frameworks of the countries involved. This publication is written by specialised employment lawyers from around the globe and addresses in-house counsels, human resources managers and legal advisors in charge of or accompanying national or international transactions.
Author: Office of The Federal Register, Enhanced by IntraWEB, LLC Publisher: IntraWEB, LLC and Claitor's Law Publishing ISBN: 016091812X Category : Law Languages : en Pages : 999
Book Description
The Code of Federal Regulations Title 26 contains the codified Federal laws and regulations that are in effect as of the date of the publication pertaining to Federal taxes and the Internal Revenue Service.
Author: Theodore D. Peyser
Author: Theodore D. Peyser
Author: Ellen S. Brody
Author: Bradley T. Borden
Author: United States. Tax Court
Author: United States. Tax Court
Author: Jens Kirchner
Author: United States. Board of Tax Appeals
Author: 
Author: Office of The Federal Register, Enhanced by IntraWEB, LLC
Author: