Table Of Content

Index to Volume 23 Title Index Combining ESOP Purchases Under Section 1042 With Other Corporate Restructuring Transactions, John B. Truskowski and John E. Curtis, Jr Combining Unaffiliated but Related Corporations: An Examination of the Proper Scope of Nonrecognition Provisions Following General Utilities Repeal, Jerred G. Blanchard, Jr. . . Compensation and Fringe Benefits, Patrick T. Navin: 401(k) Wrap- around Arrangements Compensation and Fringe Benefits, Maura Ann McBreen: Imputed Benefit Accrual Service Compensation and Fringe Benefits, Brian K. Wydajewski: Guidance for Providing Investment-Related Materials to Plan Par- PT ccbeUue aueanet ate see adts <niesccceaaabeao n Overview of Foreign Taxation of Stock Options Contingent Liabilities in Section 351 Transactions: The Service Limits the Application of Holdcroft, Steven K. Matthias Corporate Organizations and Reorganizations, Robert A. Rizzi: Contributions to Capital Under Section 108(e)(6): The Last Frontier Derivatives and Continuity of Interest: Risk Management Raises New Issues for Reorganizations Snap Shots, Successive Ownership Changes, and Other Section 382 Traps [The] Final Intercompany Transaction Regulations: Out With the Mechanical, in With the Conceptual, Bryan P. Collins and Mark A. Schneider Float Like a Deemed Butterfly . . . Reflections on the Significance of Meaninglessness in a *‘B’’ Reorganization, David B. Friedel ... . [The] Fuss About Morris Trust: Spin-Off Transactions as Acquisition Techniques, Robert A. Rizzi Index to Volume 23 Title Index Combining ESOP Purchases Under Section 1042 With Other Corporate Restructuring Transactions, John B. Truskowski and John E. Curtis, Jr Combining Unaffiliated but Related Corporations: An Examination of the Proper Scope of Nonrecognition Provisions Following General Utilities Repeal, Jerred G. Blanchard, Jr. . . Compensation and Fringe Benefits, Patrick T. Navin: 401(k) Wrap- around Arrangements Compensation and Fringe Benefits, Maura Ann McBreen: Imputed Benefit Accrual Service Compensation and Fringe Benefits, Brian K. Wydajewski: Guidance for Providing Investment-Related Materials to Plan Par- PT ccbeUue aueanet ate see adts <niesccceaaabeao n Overview of Foreign Taxation of Stock Options Contingent Liabilities in Section 351 Transactions: The Service Limits the Application of Holdcroft, Steven K. Matthias Corporate Organizations and Reorganizations, Robert A. Rizzi: Contributions to Capital Under Section 108(e)(6): The Last Frontier Derivatives and Continuity of Interest: Risk Management Raises New Issues for Reorganizations Snap Shots, Successive Ownership Changes, and Other Section 382 Traps [The] Final Intercompany Transaction Regulations: Out With the Mechanical, in With the Conceptual, Bryan P. Collins and Mark A. Schneider Float Like a Deemed Butterfly . . . Reflections on the Significance of Meaninglessness in a *‘B’’ Reorganization, David B. Friedel ... . [The] Fuss About Morris Trust: Spin-Off Transactions as Acquisition Techniques, Robert A. Rizzi INDEX TO VOLUME 23 International Developments, Howard S. Engle: Allocation of Research and Experimentation Expenditures Between U.S. and Foreign Source Income—Final Regulations Benefits of Customs Planning Controlled Foreign Corporations: Proposed Regulations Deal With Subpart F and Foreign Personal Holding Company Income. . . Final Section 482 Cost-Sharing Regulations Final Section 6662 Transfer Pricing Penalty Rules Form 5471 Revisions International Aspects of the ‘*Check the Box’’; Partnership Classifi- cation Procedure Maquiladora Update New Section 367 Temporary Regulations Instruments, Techniques, and Transactions, Robert S. Bernstein & Adam J. Buss: Clouds Gathering Over Corporate Equity Split Dollar Insurance Gifting Stock Options [The] New Section 305(c) Regulations: Past, Present, and Future, Edward J. Buchholz Private Letter Rulings, Gilbert D. Bloom: LTR 9535053: Little Ado About Something Two Questionable Spin-Off Rulings ..................00000. Recent Developments, Craig W. Friedrich: Contingent Payments Amounting to 25 Percent of Total Payments for Trademarks Found to Be ‘‘Substantial’’ and Therefore Deductible Under Section 1253 Distribution of Stock Received Upon Merger by Partnership Does Not Violate Continuity of Interest Required of Tax-Free Reor- css ube bod cbs dbbe wndec$ssdehdendcewemesv a Eighth Circuit Holds Payments for Black Lung Insurance Non- Deductible Because of Significant Future Benefits THE JOURNAL OF CORPORATE TAXATION IRS Invites Comments on Clarifying the Effect of INDOPCO on Current Deductibility Sharply Divided Tax Court Finds Investment Bankers and Printers Fees Incurred in Unsuccessful Resistance to Hostile Takeover Are Not Currently Deductible Treasury Announces Delay in Proposed Effective Date of Proposal Along Conversion of ‘‘Large’’ C Corporations to S Corpora- tions and Further Extends Proposal Value of Appreciated Assets Held Measure of Section 311(d)Gain 86 Relationship of Section 482 to International Corporate Tax Planning, Cym H. Lowell Reliable Steel Fabricators and the Practical Problem of Inventory Valuation Under the Built-In Gain Tax, Steven I. Klein Section 355 in a Post-—General Utilities World: The Victim of an Overreaction?, Melissa C. McCann Towards Reshaping the Debt-Equity Distinction, Robert A. Santangelo 312 Author Index Bernstein, Robert S. & Buss, Adam J., Instruments, Techniques and Transactions: Clouds Gathering Over Corporate Equity Split Dollar Insurance Gifting Stock Options Blanchard, Jr. Jarred G., Combining Unaffiliated but Related Corpora- tions: An Examination of the Proper Scope of Nonrecognition Provisions Following General Utilities Repeal Bloom, Gilbert D., Private Letter Rulings: LTR 9535053: Little Ado About Something Two Questionable Spin-Off Rulings Buchholz, Edward J., The New Section 305(c) Regulations: Past, Present, and Future INDEX TO VOLUME 23 Collins, Bryan P. & Schneider, Mark A., The Final Intercompany Transaction Regulations: Out With the Mechanical, in With the Conceptual Engle, Howard S., International Developments: Allocation of Research and Experimentation Expenditures Between U.S. and Foreign Source Income—Final Regulations Benefits of Customs Pianning Controlled Foreign Corporations: Proposed Regulations Deal With Subpart F and Foreign Personal Holding Company Income. . . Final Section 482 Cost-Sharing Regulations Final Section 6662 Transfer Pricing Penalty Rules Form 5471 Revisions International Aspects of the ‘“Check the Box’’; Partnership Classifi- cation Procedure Maquiladora Update New Section 367 Temporary Regulations Friedel, David B., Float Like a Deemed Butterfly . . . Reflections on the Significance of Meaninglessness in a *‘B’’ Reorganization. . . . Friedrich, Craig W., Recent Developments: Contingent Payments Amounting to 25 Percent of Total Payments for Trademarks Found to Be ‘‘Substantial’’ and Therefore Deductible Under Section 1253 Distribution of Stock Received Upon Merger by Partnership Does Not Violate Continuity of Interest Required of Tax-Free Reor- i cththtnd cabs hoiséeb esl tneces oneeanenhene Eighth Circuit Holds Payments for Black Lung Insurance Non- Deductible Because of Significant Future Benefits.......... IRS Invites Comments on Clarifying the Effect of INDOPCO on Current Deductibility Sharply Divided Tax Court Finds Investment Bankers and Printers Fees Incurred in Unsuccessful Resistance to Hostile Takeover Are Not Currently Deductible Treasury Announces Delay in Proposed Effective Date of Proposal Along Conversion of ‘‘Large’’ C Corporations to S Corpora- tions and Further Extends Proposal THE JOURNAL OF CORPORATE TAXATION Value of Appreciated Assets Held Measure of Section 311(d) Gain 86 Klein, Steven I., Reliable Steel Fabricators and the Practical Problem of Inventory Valuation Under the Built-In Gain Tax Lowell, Cym H., Relationship of Section 482 to International Corporate Planning Matthias, Steven K., Contingent Liabilities in Section 351 Transac- tions: The Service Limits the Application of Holdcroft McBreen, Maura Ann, Compensation and Fringe Benefits: Imputed Benefit Accrual Service McCann, Melissa C., Section 355 in a Post—General Utilities World: The Victim of an Overkill Navin, Patrick T., Compensation and Fringe Benefits: 401(k) Wraparound Arrangements Rizzi, Robert A., Corporate Organizations and Reorganizations: Contributions to Capital Under Section 108(e)(6): The Last Frontier Derivatives and Continuity of Interest: Risk Management Raises New Issues for Reorganizations Snap Shots, Successive Ownership Changes, and Other Section 382 Traps Rizzi, Robert A., The Fuss About Morris Trust: Spin-Off Transactions as Acquisition Techniques Santangelo, Robert A., “owards Reshaping the Debt-Equity Distinc- Truskowski, John B. & Curtis, Jr., John E., Combining ESOP Pur- chases Under Section 1042 With Other Corporate Restructuring Transactions Wydajewski, Brian K., Compensation and Fringe Benefits: Guidance for Providing Investment-Related Materials to Plan Par- ticipants Overview of Foreign Taxation of Stock Options Book Reviews FEDERAL TAX VALUATION (1996), John A. Bogdanski. Warren, Gorham & Lamont. Reviewed by Sheldon I. Banoff INDEX TO VOLUME 23 TAXATION OF DIVIDENDS AND CORPORATE DISTRIBU- TIONS, Practice and Planning (1995) Daniel M. Schneider. War- ren, Gorham & Lamont. Reviewed by Jaime M.W. Sanders U.S. TAXATION OF FOREIGN-CONTROLLED BUSINESSES (1995), edited by Marc M. Levey. Warren, Gorham & Lamont. Reviewed by Robert E. Culbertson \o Corporate Taxes in Nevada “The Delaware of the West” Set up a Nevada Holding Company If your corporation is operating in a state that taxes capital gains, dividends, interest, rents or royalties on stocks, bonds or their intangible assets, you may be able to elimi- nate the tax imposed on this income by properly setting up and maintaining a Nevada Holding Company or Investment subsidiary. Nevada Holding Services, Inc. provides Domicile Services to Corporations (including Financial Institutions), Parinerships and Limited Liability Corporations both foreign and domestic including many Fortune 500 companies. 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