Masters Theses

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Browsing Masters Theses by Department "Accounting"

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    Corporate separations ; an analysis of their tax implications
    Lamberth, George Frederick (Virginia Polytechnic Institute, 1968)
    A corporate separation is an arrangement whereby the shareholders of a single corporation split up their investment among several corporate shells through a spin-off, split-off, or split-up. The tax treatment of a corporate separation is governed by Section 355 of the Internal Revenue Code of 1954, which allows the separation of two or more existing businesses to be tax-free provided certain requirements are met. This thesis discusses and analyzes Section 355 and its related regulations in light of the various subsequent developments in order to expound the current tax treatment of corporate separations. Also, the historical development of the tax treatment of corporate separations up to 1954 is presented as background material. Basically, Section 355 desires to encourage, through tax deferment, those corporate separations which are motivated by valid business reasons, while at the same time imposing ordinary income tax on the shareholders in the case of those corporate separations which are merely being utilized as a device to distribute corporate earnings and profits at capital gain rates. Due to the possible use of a corporate separation for tax avoidance purposes, Section 355 was made very restrictive and has usually been strictly interpreted by the Internal Revenue Service and the courts. This general restrictive trend will probably continue to persist in the future. However, there appeals to be an underlying trend developing to further consider the economic results of otherwise valid corporate separations in cases where an unnecessary restrictive technicality blocks their tax-free status.
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    A study of business students and their attitudes toward accounting and other business areas of study at Virginia Polytechnic Institute
    Graham, Herbert L. (Virginia Polytechnic Institute, 1968)
    This study is an investigation of certain background and attitude factors of junior and senior students in the College of Business at Virginia Polytechnic Institute. lts purpose is to identify the nature of the image which students have of the various areas of study and the departments associated with such araas. Particular emphasis is placed upon the accounting department and the field of accountancy. Information was obtained by the use of a questionnaire. Responses were received from 89% of the junior and senior business students. The responses show that students have formulated images of each area of study in the College of Business. The students imagine a dissimilar starting salary for graduating seniors, based on their field of endeavor. They imagine that the area that receives the greatest compensation requires the most work for degree completion. Further, they feel that accounting is such a field. Most students select an itinerary between one which requires the most work with concomitant compensation and one which requires the least; work with concomitant compensation. At least 29% of the respondents, at one time or another, considered accounting as their preferred major. Yet, almost one-third of these students left accounting for other areas of study. These findings suggest that the accounting department loses students because of two problem areas: (1) the image of accounting, and (2) the method of teaching accounting. Recommendations for improving the accounting image and accounting teaching methods are made in the final chapter of the thesis.