Table Of Content

Index to Volume 20 Title Index [The] Brave New World of Consolidated Returns: An Analysis of the Recently Proposed Stock Basis Adjustment Regulations, Bryan P. Collins, P. Anthony Nissley, Lynn M. Morzorati & William J. Tiedemann Capital Assets: The Inventory Exception to Section 1221 Revisited, Ananth Seetharama Comments and Amplifications, Glen A. Kohl Corporate Organizations and Reorganizations, Robert A. Rizzi: COD Income Recognition in Type C Reorganizations Dividends and Assumption of Shareholder Debt Front-End Realignments: Non Pro Rata Contributions of Stock Before Corporate Acquisitions Quantity and Quality in the ‘Substantially All’’ Requirement .. . . [The] Depreciation of Customer Based Intangible Assets After Newark Morning Ledger, Brian R. Greenstein [The] Evolution of the Corporate Minimum Tax, Shirley A. Jones... . Extension of U.S. Stock Plans to Nonresident Aliens, Pairick T. Navin Final Regulations Under Section 512—Swap Income and Tax Qualified Pension Plans, David W. Ellis Instruments, Techniques, and Transactions, /ra Akselrad & Robert S. Bernstein: Are Expenses Incurred in Obtaining LBO Loans Deductible? . .. . New Proposed Regulations Limit the Deemed Exercise Rule for Options Under Section 382 Tax Treatment of Preferred Purchase Units Interaction of Customs and IRS Values: Recent Developments in Section 1059A, Brian J. Cody International Developments, Howard S. Engle: 413 THE JOURNAL OF CORPORATE TAXATION Branch-Profits Tax—Final Regulations Deemed Dividends in Cross-Border Section 304 Transactions.... 199 Dual Consolidated Loss Rules—Final Regulations Foreign Tax Credit Limitation Rules New Rules Concerning Limitations on U.S. Tax Benefits From Operations in Restricted Countries Taxation of Foreign Dividends Westreco Underscores Importance of Economic Analysis in Sup- porting Intercompany Transactions [The] Limited Liability Company: The New Kid in Town, Richard M. Horwood & Jeffrey A. Hechtman Liquidation Distributions: The Decision to Utilize Section 453(h), Stephen J. White & James J. Pratt Nontaxable Purchase Price Reduction Versus Taxable Disposition— The Interplay Between Sections 108(e)(5) and 453B(f), James A. Private Letter Rulings, Gilbert D. Bloom: Ability to Have a Triangular Acquisition Is Restricted Bank Holding Company/Bank Combinations Elective Retroactive Use of the Section 367 Regulations Liquidation Coupled With Some Reincorporation Recent Letter Ruling Raises Issue of Whether Section 304 Applies to a Domestic Spin-Off Transaction I 6 6 ib dina cet Ks cb dentebetererdaans Substance Over Form for the Benefit of the Taxpayer Who Can Assume Liabilities in an Acquisitive Reorganization .. . Proposed Regulations Apply Section 163(j) to Consolidated Returns and Other Affiliated Groups, Glenn E. Ferencz Recent Developments, Craig W. Friedrich: IRS Rules Advertising Remains Currently Deductible After In- Proposed Regulations Reduce Holding Period for Purposes of Dividend-Received Deduction Where Risk of Loss Is Dimin- INDEX TO VOLUME 20 Proposed Regulation Uses Single Buyer in Single Sale as Bench- mark for Valuing Inventory Service Asserts Continued Vitality of Old Revenue Ruling but Will Not Penalize Consistent Good Faith Positions Spin-Off of Newly-Formed Subsidiary Results in Recapture of Investment Tax Credit Recent Supreme Court Litigation Under ERISA, Sandra S. Cha Retirement Plan Investments in Company Stock, Maura Ann McBreen Stock Acquisitions and Liquidations by S Corporations: Availability of Benefits Afforded by Sections 332 and 338, Seth M. Zachary & Philip R. Weingold [The] Tax Free Entity Under the U.S. Flag: A U.S. Virgin Islands Exempt Company, William L. Blum Transfer Pricing: The New Section 482 Temporary and Proposed Regulations, Howard S. Engle [The] Treasury’s Debt Modification Regulations: Cottage Savings Proves a Perilous Beacon, Craig W. Friedrich United States Tax Considerations in Organizing a Foreign Joint Ven- ture, Alan P. Parnes What Constitutes a Change in Accounting Method: Is It Merely a Timing Question?, Jerome S. Horvitz & Frank B. Linton Who Really Won in Bufferd v. Comm’r, the Commissioner or Future Taxpayers?, Clay S. Harrow Author Index Akselrad, Ira & Bernstein, Robert S., Instruments, Techniques, and Transactions: Are Expenses Incurred in Obtaining LBO Loans Deductible? .... New Proposed Regulations Limit the Deemed Exercise Rule for Options Under Section 382 Tax Treatment of Preferred Purchase Units Bloom, Gilbert D., Private Letter Rulings: THE JOURNAL OF CORPORATE TAXATION Ability to Have a Triangular Acquisition Is Restricted Bank Holding Company/Bank Combinations Elective Retroactive Use of the Section 367 Regulations Liquidation Coupled With Some Reincorporation Recent Letter Ruling Raises Issue of Whether Section 304 Applies to a Domestic Spin-Off Transaction Who Can Assume Liabilities in an Acquisitive Reorganization .... 383 Blum, William L., The Tax Free Entity Under the U.S. Flag: A U.S. Virgin Islands Exempt Company Cha, Sandra S., Recent Supreme Court Litigation Under ERISA Cody, Brian J., Interaction of Customs and IRS Values: Recent Develop- ments in Section 1059A Collins, Bryan P., Nissley, P. Anthony, Morzorati, Lynn M. & Tiedemann, William J., The Brave New World of Consolidated Returns: An Analysis of the Recently Proposed Stock Basis Adjustment Regulations Ellis, David W., Final Regulations Under Section 512—Swap Income and Tax-Qualified Pension Plans Engle, Howard S., International Developments: Branch-Profits Tax—Final Regulations Deemed Dividends in Cross-Border Section 304 Transactions .. . . Dual Consolidated Loss Rules—Final Regulations Foreign Tax Credit Limitation Rules New Rules Concerning Limitations on U.S. Tax Benefits From Operations in Restricted Countries Taxation of Foreign Dividends Westreco Underscores Importance of Economic Analysis in Sup- porting Intercompany Transactions Engle, Howard S., Transfer Pricing: The New Section 482 Temporary and Proposed Regulations Ferencz, Glenn E., Proposed Regulations Apply Section 163(j) to Consolidated Returns and Other Affiliated Groups INDEX TO VOLUME 20 Friedrich, Craig W., Recent Developments: IRS Rules Advertising Remains Currently Deductible After Indopco 301 Proposed Regulations Reduce Holding Period for Purposes of Dividend-Received Deduction Where Risk of Loss Is Diminished 399 Proposed Regulation Uses Single Buyer in Single Sale as Bench- mark for Valuing Inventory 303 Service Asserts Continued Vitality of Old Revenue Ruling but Will Not Penalize Consistent Good Faith Positions 109 Spin-Off of Newly-Formed Subsidiary Results in Recapture of Investment Tax Credit 107 Friedrich, Craig W., The Treasury’s Debt Modification Regulations: Cottage Savings Proves a Perilous Beacon 151 Greenstein, Brian R., The Depreciation of Customer Based Intangible Assets After Newark Morning Ledger 315 Harrow, Clay S., Who Really Won in Bufferd v. Comm’r, the Commis- SIF IT 6 o 5'0 cr ececaceccvedesescnccs 326 Horvitz, Jerome S. & Linton, Frank B., What Constitutes a Change in Accounting Method: Is It Merely a Timing Question? 265 Horwood, Richard M. & Hechtman, Jeffrey A., The Limited Liability Company: The New Kid in Town 334 Jones, Shirley A., The Evolution of the Corporate Minimum Tax 351 Kohl, Glen A., Comments and Amplifications 78 McBreen, Maura Ann, Retirement Plan Investments in Company Stock 87 Navin, Patrick T., Extension of U.S. Stock Plans to Nonresident Aliens Orefice, James A., Nontaxable Purchase Price Reduction Versus Taxable Disposition—The Interplay Between Sections 108(e)(5) and 453B(f) Parnes, Alan P., United States Tax Considerations in Organizing a Foreign Joint Venture Rizzi, Robert A. , Corporate Organizations and Reorganizations: COD Income Recognition in Type C Reorganizations Dividends and Assumption of Shareholder Debt Front-End Realignments: Non-Pro Rata Contributions of Stock Before Corporate Acquisitions Quantity and Quality in the ‘‘Substantially All’’ Requirement ... . 418 THE JOURNAL OF CORPORATE TAXATION Seetharaman, Ananth, Capital Assets: The Inventory Exception to Section 1221 Revisited 164 White, Stephen J. & Pratt, James J., Liquidation Distributions: The Decision to Utilize Section 453 (h) Zachary, Seth M. & Weingold, Philip R., Stock Acquisitions and Liquidations by S Corporations: Availability of Benefits Af- forded by Sections 332 and 338