book: Constructive ownership rules and related party transactions.: An article from: The Tax...

book: Constructive ownership rules and related party transactions.: An article from: The Tax Adviser | Albert B. Ellentuck

books:

Constructive owner...

	Constructive ownership rules and related party transactions.: An article from: The Tax Adviser Albert B. Ellentuck American Institute of CPA's, 1994 - 3 pages
	for more information click here

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on March 1, 1994. The length of the article is 756 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: The ownership interests of related parties must be considered in a partnership setting when entering into a related party transaction because tax restrictions on such transactions are based on constructive as well as actual ownership. Constructive ownership may require that related interests, such as interests held by family members, partners or subsidiaries, be aggregated with interests actually held by the individual. This aggregation may cause a partner to exceed the 50% limit on interest in the related party, resulting in ordinary income treatment.

Citation Details
Title: Constructive ownership rules and related party transactions.
Author: Albert B. Ellentuck
Publication: The Tax Adviser (Magazine/Journal)
Date: March 1, 1994
Publisher: American Institute of CPA's
Volume: 25 Issue: n3 Page: 178(1)

Distributed by Thomson Gale

for more information click here

ownership