See, e.g., 26 USC 385. The Internal Revenue Service had proposed complex regulations under this section (see TD 7747, 1981-1 CB 141) which were soon withdrawn (TD 7920, 1983-2 CB 69). An article in Tax Notes, a publication of Tax Analysts in 1986 [citation needed] identified 26 factors the U.S. courts have used to classify instruments as debt or equity. Also see article[permanent dead link] by Englebrecht, et al.
See, e.g., 26 USC 385. The Internal Revenue Service had proposed complex regulations under this section (see TD 7747, 1981-1 CB 141) which were soon withdrawn (TD 7920, 1983-2 CB 69). An article in Tax Notes, a publication of Tax Analysts in 1986 [citation needed] identified 26 factors the U.S. courts have used to classify instruments as debt or equity. Also see article[permanent dead link] by Englebrecht, et al.
26 USC 1(h)(11). Distributions from an S corporation, Regulated Investment Company (mutual fund), or Real Estate Investment Trust are not treated as dividends.
Liu, Li (2011). The economic effects of corporate income taxation (PhD Thesis). Rutgers University - Graduate School - New Brunswick. doi:10.7282/T3765DZR.
Desai, Mihir A.; Foley, C. Fritz; Hines, James R. "Labor and Capital Shares of the Corporate Tax Burden: International Evidence". CiteSeerX10.1.1.364.4867. {{cite journal}}: Cite journal requires |journal= (help)
