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LAUR's Partial Liquidation Falls Within Section 302(e)(2)
November 26, 2021
The taxpayer, ("TP"), is a publicly traded domestic corporation that owns T. TP is Laureate Education, Inc., ("LAUR"). T owns TS. Each of T and TS is a disr...

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Recent Reports

Sec. 6426 Credits Reduce Deductible Excise Tax Liability
November 26, 2021
The question is whether, for federal income tax purposes, the credits allowed under Sec. 6426(a) reduce a claimant's liability for excise taxes. Claimants typically include...
Legal Incidence Not Economic Burden (Of A Tax) Is Controlling
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Increased Assessment Not An Illegal "Spot Assessment"
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Investment Manager Did Not Add Substantial New Line Of Business
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X is a publicly traded partnership (PTP) that is an "electing 1987 partnership" under Sec. 7704(g). Since its inception, X has been engaged in the business...