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15 results on '"Heller, Kenneth H."'

3. Check-the-box final regs. simplify entity classification.

Author

Heller, Kenneth H. and Carnevale, Michael K.

Subjects
Limited liability companies -- Taxation -- Laws, regulations and rules, Tax elections -- Laws, regulations and rules, Foreign business enterprises -- Taxation -- Laws, regulations and rules, Partnership -- Taxation -- Laws, regulations and rules, Corporate income taxes -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 7701)
Abstract

The Sec. 7701 final regulations succeed to a great extent in providing a simple elective method for classifying an entity, while also providing specific classifications for certain types of entities. [...]

Published
1997

4. 'To the extent' provisions: when do they operate without regulations?

Author

Crnkovich, Robert J. and Heller, Kenneth H.

Subjects
Tax administration and procedure -- Laws, regulations and rules, Delegated legislation -- Cases, Alexander (95 T.C. 467 (1990))
Abstract

Two Tax Court decisions show ambiguity about when compliance with a law is possible without accompanying regulations. The Alexander case required regulations to trigger a statute, for Treasury Department rules on at-risk financing. But the Traylor case did not require rules for discharge of debt to be classed as ordinary income. Laws with 'to the extent provided' language should be treated as if the regulations do not apply until actually in existence.

Published
1992

5. Merger and division prop. regs.

Author

Orbach, Kenneth N. and Heller, Kenneth H.

Subjects
Partnership -- Mergers, acquisitions and divestments, Acquisitions and mergers -- Taxation, Company acquisition/merger
Abstract

Until recently, the only available guidance on partnership mergers and divisions was a smattering of revenue and letter rulings. Earlier this year, Treasury released proposed regulations on such transactions; the [...]

Published
2000

15. Interrelationships of Sections 731, 736, and 751: A Worksheet Approach.

Author

Streuling, G. Fred, Boyd, James H., and Heller, Kenneth H.

Subjects
TAXATION, BUSINESS partnerships, DECISION making, LIQUIDATION, PARTNERSHIP dissolution (Business), CORPORATE distributions, CORPORATION law, CORPORATE divestiture
Abstract

It is clear from the statutes that most distributions in liquidation of a partnership interest that involve some cash payments are subject to the provisions of three Code sections: Sections 731, 736, and 751. It is critical to understand in what sequence the provisions of all three sections are applicable. To facilitate the proper use of the intricate rules, the authors have developed a worksheet approach that is designed to apply the appropriate provisions in their correct sequence. Initially, this approach may require a considerable start-up effort. However, once the concepts have been mastered, the worksheet becomes an indispensable tool that converts a difficult and tedious task to a programmed decision process which simplifies the task, eliminates errors, and may be adaptable to the computer. [ABSTRACT FROM AUTHOR]

Published
1987

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