Special report on taxation. New IRS revenue procedure clarifies tax classification of limited liability companies

Although its rules are complex, the publication of Revenue Procedure 95-10 will substantially facilitate the use of LLCs in those states with statutes that permit significant flexibility in the structuring of LLCs. Previously, the only way to assure that LLCs in those states would be classified as partnerships for income tax purposes was to obtain a private letter ruling from the IRS, often resulting in lengthy delays. The new revenue procedure should provide sufficient guidance in the vast majority of cases to allow tax counsel to determine the appropriate treatment for tax purposes without having to seek an IRS private letter ruling.     

From underworld to underground

In the West economically motivated crime is usually perceived as a matter for the police while the performance of the economy is a matter for the political authorities. This paper argues that the growth and evolution of the modern underground economy has made such a distinction obsolete. Not only have the frontiers between the legitimate and the criminal sectors of the economy blurred, but the distinction between the explicitly criminal and the merely informal aspects of the modern underground economy has become largely meaningless. Given the tremendous growth of underground activity, this means that the issue must now be addressed not just on the enterprise level, as a police matter, but on the level of the economy as a whole, by economic policy makers. This in fact is something that many developing countries long ago realized. The paper therefore asks whether developing countries have been any more successful in using monetary, fiscal and balance of payments policy to mitigate the adverse social and economic impact of widespread underground economic activity than have Western countries who have relied mainly on the sanction of criminal law. It concludes that both approaches are deficient in so far as they neglect the degree to which modern underground activity can no longer be seen as a manifestation of deviant economic behavior so much as a virtual economic insurgency against the status quo distribution of income and wealth and the codes of economic behavior which accompany it. However dramatic are the financial manifestations of the spread of enterprise crime, ultimately the challenge it poses must be addressed as the political and ideological level.     

Population: malady or symptom?

The 1994 International Conference on Population and Development (ICPD) opened the dawn of a new era in discourse over population. A newfound consensus was reached between North and South which was not there during the two previous world population conferences in Bucharest and Mexico. While consensus was reached at the 1994 ICPD on the need for action, however, debate over population is far from settled. Causes of population growth, the links between population growth and economic development, and environmental degradation remain controversial topics. The authors analyze the basis of the ICPD consensus at the local, national, and global levels. They also compare the development discourse to the political discourse over population. Both discourses emphasize different aspects of a far more complex reality. The question is which discourse to choose as a basis for drawing policy recommendations. The emerging view on the way to Cairo was that consensus would be achieved on the basis of development discourse. Success on the action plan rests upon the belief that more contraceptives, more health services, and more schools will be enough to reduce fertility rates. The political discourse, however, is better than the development discourse as a basis for policy making because it stresses the need for integration rather than running the risk of exclusion. The political discourse is also more demanding.     

Must the show go on? The case for Theatre For Development

This article discusses the reasons for use and nonuse of folk theater for communicating development messages. Theater for Development (TFD) is a tool used by development agencies for improving the quality of life among vulnerable populations. TFD uses fiction and the "safe space" of performance to comment on reality and offer alternatives. The medium offers the opportunity to explore roles that would normally be denied in real life and to explore a community's developmental aspirations. Most TFD draws on talent from the dramatic arts that is unfamiliar with development perspectives. TFD is finally being recognized as important for cultural expression suitable for self-development. Communication is the single most important aspect in the process of development. The constraints to TFD are lack of inclusion within development policy, the lack of development artists, and most importantly, time. Groups with a history of silence, oppression, and marginalization need facilitators. The Freirean model is a consciousness raising one. Participatory theater is centuries old. The most vigorous, sustained TFD theaters are in places with deprivation, poverty, disease, and hunger. These situations are well suited to TFD as a critical intervention for change. An example from the Nigerian Popular Theater Alliance is used to illustrate consciousness raising about government provision of services. TFD allows communities to draw agendas of their own. India has a substantial tradition of Social Action Groups and street theater. TFD can reverse power relations, is not dependent on literacy, and offers an entertaining way of spreading information.     

Congress advances on health care reform: one step at a time

In adopting the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Congress made a series of small but significant steps toward improving access to health care benefits. The Act's centerpiece is its new requirements for group health plans and for the health insurance industry for assuring portability, access, and renewability of health insurance coverage. Of nearly equal importance is the pilot program established for testing the viability of medical savings accounts. Other health-related changes include adjustments in the rules governing duplication and coordinating of Medicare-related plans, recommendations with respect to privacy of health information of employees, an increase in the deduction for health insurance costs for self-employed individuals, and permission for unemployed persons to make withdrawals from IRAs and other qualified plans for certain medical services' costs. This article summarizes these and other key provisions of HIPAA.     

Reviews

Roman Szporluk (ed.), National Identity and Ethnicity in Russia and the New States of Eurasia. New York and London: M.E. Sharpe, 1994, xiii + 328 pp., £40.00 h/b, £16.00 p/b.

Paul Kolstoe, Russians in the Former Soviet Republics. London: Hurst, 1995, xii + 340 pp., £35.00.

Ronald Grigor Suny, The Révenge of the Past. Nationalism, Revolution and the Collapse of the Soviet Union. Stanford: Stanford University Press, 1993, xix + 207 pp., £25.00 h/b, £10.95 p/b.

Ian Bremmer & Ray Taras (eds), Nations and Politics in the Soviet Successor States. Cambridge: Cambridge University Press, 1993, xxvii + 557 pp., £55.00 h/b, £17.95 p/b.

Charles A. Kupchan (ed.), Nationalism and Nationalities in the New Europe. Ithaca & London: Cornell University Press, 1995, xi + 224 pp., £31.50 h/b, £11.95 p/b.

Christopher Williams, AIDS in Post‐Communist Russia and its Successor States. Aldershot: Avebury, 1995, xvi + 216 pp., £35.00.

Amin Saikal & William Maley (eds), Russia in Search of its Future. Cambridge: Cambridge University Press, 1995, xii + 239 pp., £30.00 h/b, £10.95 p/b.

Marco de Andreis & Francesco Calogero, The Soviet Nuclear Weapon Legacy. New York: Oxford University Press, 1995, x + 130 pp., £25.00.

Eva Haraszti‐Taylor, The Hungarian Revolution of 1956. A Collection of Documents from the British Foreign Office. London: Astra Press, 1995, xxxii + 404 pp., £5.95.

Julian Cooper, Maureen Perrie & E. A. Rees (eds), Soviet History, 1917–53: Essays in Honour of R. W. Davies. London and Basingstoke: St Martin's Press, 1995, xxviii + 273 pp. £45.00.

Tsentral'nyi gosudarstvennyi arkhiv Sovetskoi Armii. Putevoditel’ v dvukh tomakh. Minneapolis: East View Publications, Vol. 1, v + 421 pp., Vol. 2, vi + 531 pp., 1991, 1993, £59.00.

Vladimir N. Brovkin, Behind the Front Lines of the Civil War: Political Parties and Social Movements in Russia, 1918–1922, Princeton, NJ: Princeton University Press, 1994, xiv + 455 pp.

Semion Lyandres, The Bolsheviks’ ‘German Gold’ Revisited: An Inquiry into the 1917 Accusations. Pittsburgh: Carl Beck Papers No. 1106, Center for Russian and East European Studies, University of Pittsburgh, 1995, 132 pp., no price.

Al Richardson (ed.), In Defence of the Russian Revolution: A Selection of Bolshevik Writings. 1917–1923. London: Porcupine Press, 1995, xvi + 287 pp., £12.99.

Neil Robinson, Ideology and the Collapse of the Soviet System. A Critical History of Soviet Ideological Discourse. Aldershot: Edward Elgar, 1995, x + 227 pp., £45.00.

Alexsandras Shtromas (ed.), The End of “Isms"? Reflections on the Fate of Ideological Politics after Communism's Collapse. Oxford: Blackwell Publishers, 1995, 234 pp., £13.99.

Simon Tormey, Making Sense of Tyranny: Interpretations of Totalitarianism. Manchester: Manchester University Press, 1995, vi + 199 pp., £7.95.

David L. Hoffmann, Peasant Metropolis: Social Identities in Moscow, 1929–1941. Ithaca and London: Cornell University Press, 1994, xv + 282 pp., £26.95.

Heather Hogan, Forging Revolution: Metalworkers, Managers, and the State in St. Petersburg, 1890–1914. Bloomington, IN: Indiana University Press, 1993, xviii + 319 pp., £32.50.

Marjorie Mandelstam Balzer (ed.), Culture Incarnate: Native Anthropology from Russia. Armonk, New York, London: M.E. Sharpe, 1995, xii + 270 pp.

Michael D. Kennedy (ed.), Envisioning Eastern Europe: Postcommunist Cultural Studies. Michigan: University of Michigan Press, 1994, 249 pp., £30.00.

Blanche H. Gelfant, Cross‐Cultural Reckonings: A Triptych of Russian, American, and Canadian Texts. Cambridge: Cambridge University Press, 1995, x + 190 pp., £35.00.