The latest installment of the Institute’s ongoing Federal Income Tax Project, an extensive Reporters’ Study by George K. Yin of the University of Virginia and David J. Shakow of the University of Pennsylvania on Taxation of Private Business Enterprises, will be published in mid-August.

The new Reporters’ Study explores in depth the consequences of the flexibility presently available to owners of private business enterprises to determine how their businesses should be classified for federal income-tax purposes and thus the extent of their income-tax liability. In the interests of greater fairness, consistency, and simplicity, the Study recommends that current law should be replaced by a system whereby all private business firms, no matter what their form of organization and organizational characteristics, would be taxed as conduits for income-tax purposes, with tax liability passed through the company to the individual owners. It sets forth a coherent set of specific proposals, drawing upon modified versions of the present rules for Subchapters K and S, to that end.

Because it was the view of most of the project’s Consultants and Advisers that a fully satisfactory solution to the problems presented had not been achieved but that the analysis and recommendations were stimulating and valuable, it was decided not to attempt to reach a consensus on the floor of the Institute but instead to publish the work as a Reporters’ Study. The 496-page softbound volume (order no. 6135) will be available from the Institute at the regular price of $50, plus shipping and handling. It will be available to all ALI members, however, at half price, $25, plus shipping and handling. Orders should be placed with the Institute’s Customer Service Department, 4025 Chestnut Street, Philadelphia, PA 19104-3099 (telephone: 1-800-CLE-NEWS, extension 7000; fax: 215-243-1664; online: http://www.ali.org).