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64 Taxes 1 (1986)

handle is hein.journals/taxtm64 and id is 1 raw text is: . 7/st TAX MAGAZINE This magazine is pub- [lished to promote sound thought in economic, legal and accounting principles relating to all federal and state taxation. To this Dnd it contains signed articles on tax subjects of current interest and re- ports by the OCH Editorial Staff on recent federal and state tax matters. The editorial policy Is to allow frank discussion of tax issues. On this basis contributions are invited. Responsibility Is not as- sumed for the contents of the articles or for the )pinions expressed therein. gditor Gene 0. SJostrand Washington Editor James R. McNeilis fsiness Manager James A. Merchant 2irculation Manager Donald B. Izban TAXES-The Tax Maga- zine (ISSN 0040-0181) is published monthly by Commerce Clearing House, Inc., 4025 W. Peterson Ave., Chicago, IL 60646. Second-class postage paid at Chicago, Illinois. POST- MASTER: SEND AD- DRESS CHANGES TO TAXES-The Tax Maga- zine, 4025 W. PETERSON AVE., CHICAGO, ILLI- NOIS 60646. Subscription rate: $75. 1 year; $8 single copy. January 1986. Vol. 64, No. 1. Change of ad- dress should be received at least 30 days before the date of the issue with which it Is to take effect. 0 1985, Commerce Clear- Ing House, Inc. All rights reserved. Printed in U.S.A. JANUARY 1986 * VOL. 64 No. 1 T ax N ote s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Transfers of Technology: The Appropriateness of Capital Gain Treatment 3 Robert D. Heyde examines two theories that may determine that a transfer of all substantial rights in developed technology that otherwise meets 'the requirements for capital gain treatment should be treated as resulting in ordi- nary income. Innovative Transactions .. ..................................... 13 In the first of a series of articles, Douglas A. Walter and Paul A. Strasen discuss the tax consequences of the offering of securities of Rockefeller Center, Inc. Domestic Corporations with Foreign Subsidiaries, Beware: NOLs Can Result in Double Taxation of Foreign-Source Dividends . .. . 17 Richard M. Lipton and Sandra G. Filler address the problem of double taxa- tion of foreign-source dividends. The Fifth Amendment Privilege for Corporate Documents: The Latest Chapter ................................................ ... 24 Two recent cases concerning the right of a corporate officer to assert the Fifth Amendment privilege against self-incrimination when corporate records have been subpoenaed are focused on by Elliot Silverman. In W ashington ............................................ 28 New Regulations Detail the Application of the Economic Performance Requirement ..... ................................. ... : ... 29 Thomas L. Dickens analyzes newly issued temporary regulations that provide answers to the uncertainties of the concept of economic performance in limit- ing the premature accrual of deductions by accrual-basis taxpayers. Incorporation of Professionals Still Offers Benefits .................. 38 The benefits offered by a professional corporation over'those of a professional practice are reviewed by Robert W. Wood. Does the Cessation of Movie Revenue Trigger the Recapture of Invest- ment Credit? ... ..................................... . ... 44 Rick E. Norris examines the likelihood that taxpayers may successfully elect the 90 percent method of computing investment credit for movies distributed through various media when there has been a cessation of movie revenue. State Taxes .. ..................... 51 Rev. Rul. 79-347 Revisited: Is the Commissioner an Expert Mathema- tician? ... ............................. ........ . . . :'.: ... 52 An alternative solution to the IRS's equations for simultaneously determining the dividends-received and percentage depletion deductions for a corpora- tion when it has been determined that the corporation has'net income is pre- sented by Jack Robison and Richard S. Mark. Cases and Rulings Enhance the Viability of Substantially Disproportionate Redem ptions ........ .......... ...... . .. 59 Henri C. Pusker considers the structuring and tax treatment of substantially disproportionate redemptions by shareholders of closely held corporations. Tax Meetings .. .............................................. 64

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