Home      Login


Structuring the Closely Held Enterprise for Dynamic Growth (With a Focus on the Restaurant/Bar Industry)  


Author:  David Randall Jenkins.


Source: Volume 35, Number 03, Spring 2018 , pp.33-62(30)




Journal of Taxation of Investments

next article > |return to table of contents

Abstract: 

Complicated closely held capital arrangements can lead to improved economies of scale and lower equity costs of capital, approaching publicly held capital economics. This article shows how incremental factors can develop closely held businesses for dynamic growth. These factors involve (1) Whiteco Industries, Inc. modular structure tangible personal property factors in relation to the transitory special-allocation conclusive presumption, (2) C corporation environment FLSA and Section 45B credit strategies, and (3) Affordable Care Act, ERISA, and multiple tax benefit controlled group considerations.

Keywords: Whiteco Industries, Inc. modular structure tangible personal property factors, accelerated depreciation, IRC Sec. 179, IRC Sec. 168(k), start-up partnerships, capital partners, licensing partners, operating partners, partnership allocations, ERISA an

Affiliations:  1: Algorithm LLC.

Subscribers click here to open full text in PDF.
Non-subscribers click here to purchase this article. $30

next article > |return to table of contents