Code Section 304 requires the reclassification of stock sales between affiliated corporations as dividends. However, for many years, Code Section 304 has not fulfilled the original “anti-avoidance” tax policy that was behind its legislation. This article aims to provide an updated analysis...

In this article, McCoskey and Narotzki explain why the basis rules under section 358 require tweaking when, in exchange for stock, a transferor of property also receives an installment note with excess basis

Affiliated corporations can elect to file a consolidated tax return, thereby using the losses from some members to offset the income of other members. To prevent this strategy from being used by multinational entities, the Dual Consolidated Loss rules prohibit the use of a loss in the United...

In this article, McCoskey and Narotzki argue that Congress needs to shift its focus to long-term economic recovery measures, and they explain how specific tax policies could be used to achieve that goal

With promises of “Make America Great Again” and tax reform for “middle-class” Americans, the current federal government administration has implied that the average American would become more prosperous under this tax system. It is no surprise that most middle-class Americans view a...

The Trump Administration, along with the House Ways and Means Committee and the Senate Finance Committee, issued a “Unified Framework” for tax reform on September 27, 2017. This framework is full of paradoxes and inconsistencies that are very hard to simply explain by saying that the...

Nations rely on taxes to fund their activities and services. Because each nation’s tax revenue is predominantly generated from domestic sources, the right to tax is clearly of domestic origin. However, the current state of trade relations involves multinational and foreign corporations, as...

In this report, Narotzki argues that corporate inversions are not as harmful as they are portrayed to be and that the government efforts may be better spent by allowing inversions or reforming the tax code to encourage businesses to remain domiciled in the United States

With increased technology and access to information, corporations have evolved in order to reflect the concept of corporate social responsibility (CSR) in their global business strategies. Some companies, such as Starbucks Corporation, have taken this concept a step further and chose to...