Search

Your search keyword '"Choate, Gary M."' showing total 22 results
Start Over Author "Choate, Gary M."
22 results on '"Choate, Gary M."'

2. More on consolidated returns and the single entity-theory: the new intercompany transaction proposed regs.

Author

Choate, Gary M., Mason, Donald J., and Gillette, Michele R.

Subjects
Affiliated corporations -- Taxation -- Laws, regulations and rules, Tax returns -- Laws, regulations and rules, Related party transactions -- Taxation -- Laws, regulations and rules, Dividends -- Taxation -- Laws, regulations and rules, Government regulation, Company dividends, Internal Revenue Code (I.R.C. 1502) (I.R.C. 267(f))
Abstract

On Apr. 8, 1994, the IRS issued proposed regulations(1) under Sec. 1502 that revise the intercompany transaction system of the consolidated return regulations. The goal is to ensure, when practical [...]

Published
1995

3. Consolidated returns and the single-entity theory: the new intercompany transaction proposed regs.

Author

Choate, Gary M. and Mason, Donald J.

Subjects
Tax returns -- Laws, regulations and rules, Related party transactions -- Taxation -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 1502)
Abstract

On Apr. 8, 1994, the IRS issued anxiously awaited proposed regulations(1) under Sec. 1502 that revise the intercompany transaction system of the consolidated return regulations. The goal is to ensure, [...]

Published
1994

4. The Revenue Reconciliation Act of 1993 attacks the conversion of ordinary income to capital gain; additional changes are aimed at limiting benefits from capital gains.

Author

Mason, Donald J. and Choate, Gary M.

Subjects
Capital gains tax -- Analysis, Recognition of gain or loss (Taxation) -- Analysis, Capital stock -- Taxation -- Analysis, Partnership -- Taxation -- Analysis, Preferred stocks -- Taxation -- Analysis, Omnibus Budget Reconciliation Act of 1993, Internal Revenue Code (I.R.C. 1258)
Abstract

The Revenue Reconciliation Act of 1993 (RRA) raised the top marginal tax rate on ordinary investment income for noncorporate taxpayers to 39.6%, while retaining the pre-RRA maximum tax rate of [...]

Published
1993

5. Final sec. 707 regulations.

Author

Mason, Donald J. and Choate, Gary M.

Subjects
Transfer (Law) -- Laws, regulations and rules, Partnership -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 707) (I.R.C. 737)
Abstract

The IRS issued the final regulations(1) under Sec. 707 covering disguised sales of property between partners and partnerships on Sept. 25, 1992. The final regulations made some improvements, but overall [...]

Published
1993

6. The loss disallowance rule - round three; is this the final chapter?

Author

Mason, Donald J. and Choate, Gary M.

Subjects
Subsidiary corporations -- Taxation -- Laws, regulations and rules -- Analysis, Loss deductions -- Analysis -- Laws, regulations and rules, Tax deductions -- Laws, regulations and rules -- Analysis, Government regulation
Abstract

The IRS issued the final regulations covering the loss disallowance rule (LDR) on Sept. 13, 1991. Anyone familiar with the history of these regulations might wonder whether it was simply [...]

Published
1992

9. The loss disallowance rule - round two.

Author

Mason, Donald J. and Choate, Gary M.

Subjects
Corporations -- Taxation, General Utilities doctrine (Taxation) -- Laws, regulations and rules, Recognition of gain or loss (Taxation) -- Laws, regulations and rules, Internal Revenue Code (I.R.C. 337(d)), Internal Revenue Code (I.R.C. 1502)
Published
1991

10. Restructuring leveraged buyouts.

Author

Mason, Donald J., Grudzinski, Chester W., Jr., and Choate, Gary M.

Subjects
Corporate reorganizations -- Laws, regulations and rules, Leveraged buyouts -- Laws, regulations and rules
Published
1991

16. The new S corporation in oil and gas.

Author

Massoglia, Donald J. and Choate, Gary M.

Subjects
Petroleum -- Taxation, Natural gas -- Taxation, S corporations -- Taxation
Published
1983

20. Prepaid IDC and Keller - what happened to previous criteria?

Author

Choate, Gary M., Massoglia, Donald J., and Tompkins, John H., Jr.

Subjects
Expense deductions -- Analysis, Oil well drilling -- Taxation, Keller v. Commissioner (79 T.C. No. 2 (1982)), Stradlings Building Materials, Inc. (76 T.C. 84 (1981)), Internal Revenue Code (I.R.C. 263(c)), Internal Revenue Code (I.R.C. 446(b))
Published
1983

21. Only one way to change to bad debt reserve.

Author

Choate, Gary M., Massoglia, Donald J., Kupfer, T. Milton, and Kruger, Daniel F.

Subjects
Reserves (Accounting) -- Laws, regulations and rules, Business losses -- Accounting and auditing, Loss deductions -- Analysis
Published
1985

Catalog

Books, media, physical & digital resources
See catalog results