2007
DOI: 10.3167/isf.2007.220108
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“…3 Another provision, attributes items of income, deduction, credit, and other allowances to the employee-owners of a professional corporation formed with the principal purpose of diverting tax liability from the owners. 5 Administrative regulations also contain targeted anti-avoidance rules ("TAARs"). Thus, the restructure of a transaction as a sale to an unrelated third party who immediately re-sells the asset to the intended related party would not achieve allowance of the loss because the statute itself negates losses on indirect sales as well.…”
Section: Regulation Of Tax Avoidance -In Generalmentioning
confidence: 99%
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“…3 Another provision, attributes items of income, deduction, credit, and other allowances to the employee-owners of a professional corporation formed with the principal purpose of diverting tax liability from the owners. 5 Administrative regulations also contain targeted anti-avoidance rules ("TAARs"). Thus, the restructure of a transaction as a sale to an unrelated third party who immediately re-sells the asset to the intended related party would not achieve allowance of the loss because the statute itself negates losses on indirect sales as well.…”
Section: Regulation Of Tax Avoidance -In Generalmentioning
confidence: 99%
“…Those contained in the conduit financing rules under Regs. 5 IRC §267(a)(1). Partnership anti-abuse regulations limit the ability to organize a business as a partnership in order to reduce tax liability of partners in a manner inconsistent with the intent of the partnership provisions.…”
Section: Regulation Of Tax Avoidance -In Generalmentioning
confidence: 99%
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