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Tax Debt Help – Settlement & Negotiation, Lissa Coffey
Tax Debt Help – Settlement & Negotiation, Lissa Coffey
LissaCoffey
Get helpful tips, advice and help with debt or any kind of irs help on setting up payment plans, requesting affordable installment agreements, reducing your tax debts through an Offer in Compromise, or discharging your tax debts through bankruptcy. Tags: GET-OUT-OF-IRS-TAX-DEBT, irs tax help, tax relief help, IRS-PAYMENT-PLAN, irs debt, irs help, help with debt, help with tax debt
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham
Pace Law Review
In order to promote both equality and efficiency, this Comment proposes that individuals should have the opportunity to file jointly for tax and bankruptcy purposes when they have a relationship predicated upon economic interdependence, as opposed to basing the opportunity to file jointly upon marital status. Part I of this Comment will briefly discuss the history of marriage in the United States. In particular, Part I will discuss the role that the government has had in promoting and regulating marriage and how the treatment of married persons operates to the exclusion of the unmarried. Parts II and III of this …
Tax Recognition, Barry Cushman
Tax Recognition, Barry Cushman
Barry Cushman
This article was prepared for the St. Louis University Law Journal’s “Teaching Trusts & Estates” issue. Many law students take a course in Trusts & Estates, but comparatively few enroll in a class devoted to the federal wealth transfer taxes. For most law students, the Trusts & Estates course provides the only opportunity for exposure to some of the basic features of the estate tax, the gift tax, the generation-skipping transfer tax, and some related features of the income tax. The coverage demands of the typical Trusts & Estates course do not allow for intensive discussion of these issues, but …
Why Congress Adopted The Church Audit Procedures Act And What Must Be Done Now To Restore The Law For Churches And The Irs, J. Michael Martin
Why Congress Adopted The Church Audit Procedures Act And What Must Be Done Now To Restore The Law For Churches And The Irs, J. Michael Martin
Akron Tax Journal
This Article explores the significant policy purposes achieved by CAPA through the lens of the law's history and present challenges. Part II reviews the historical context and events leading to the adoption of CAPA in 1984. Part III then describes the present challenges associated with the law due to the failure of Congress and the Treasury Department to rectify the issue of who is an appropriate high-level Treasury official under CAPA. Finally, Part IV concludes with recommended solutions for restoring the law consistent with congressional intent in adopting CAPA-solutions that could easily be achieved through a simple amendment to the …
A Proposed Replacement Of The Tax Expenditure Concept And A Different Perspective On Accelerated Depreciation, Douglas A. Kahn
A Proposed Replacement Of The Tax Expenditure Concept And A Different Perspective On Accelerated Depreciation, Douglas A. Kahn
Articles
Over 32 years ago, I published an article on accelerated depreciation in which I concluded that some amount of acceleration was consistent with normal tax principles and should not be classified as a tax expenditure. Over the intervening years, from time to time, I have exchanged comments with authors who have questioned that conclusion. It is time to revisit that topic and renew the consideration of how tax depreciation may properly operate. This Essay’s analysis of depreciation provides one example of how the tax expenditure budgets are flawed. The treatment of some accelerated depreciation as a tax expenditure is based …
Understanding The Amt, And Its Unadopted Sibling, The Amxt, James R. Hines Jr., Kyle D. Logue
Understanding The Amt, And Its Unadopted Sibling, The Amxt, James R. Hines Jr., Kyle D. Logue
Articles
Four million Americans with extensive tax preferences are subject to the Alternative Minimum Tax (AMT). By taxing a broad definition of income, the AMT makes it possible to have a tax system that both encourages certain activities with generous tax preferences and maintains a semblance of distributional equity. The same rationale supports the imposition of an Alternative Maximum Tax (AMxT), which would cap tax liabilities of individuals with very few preference items and thereby afford Congress greater flexibility in designing the income tax. The original 1969 AMT proposal included an AMxT; it is difficult to justify imposing one without the …
Corporate Taxation And Corporate Social Responsibility, Reuven S. Avi-Yonah
Corporate Taxation And Corporate Social Responsibility, Reuven S. Avi-Yonah
Articles
This Article will address the question of whether publicly traded U.S. corporations owe a duty to their shareholders to minimize their corporate tax burden through any legal means, or if instead, strategic behaviors like aggressive tax-motivated transactions are inconsistent with corporate social responsibility (“CSR”). I believe the latter holds true, regardless of one’s view of the corporation. Under the “artificial entity” view, such behavior undermines the constitutive relationship between the corporation and the state. Under the “real view,” such behavior runs contrary to the normal obligation of citizens to comply with the law (even absent effective enforcement). And under the …
Tax Recognition, Barry Cushman
Tax Recognition, Barry Cushman
Journal Articles
This article was prepared for the St. Louis University Law Journal’s “Teaching Trusts & Estates” issue. Many law students take a course in Trusts & Estates, but comparatively few enroll in a class devoted to the federal wealth transfer taxes. For most law students, the Trusts & Estates course provides the only opportunity for exposure to some of the basic features of the estate tax, the gift tax, the generation-skipping transfer tax, and some related features of the income tax. The coverage demands of the typical Trusts & Estates course do not allow for intensive discussion of these issues, but …
Cameos From The Margins Of Conjugality, Kim Brooks
Cameos From The Margins Of Conjugality, Kim Brooks
Articles, Book Chapters, & Popular Press
This chapter uses the changes to the legislation in Canada’s Income Tax Act, implemented by the Modernization of Benefits and Obligations Act, and the subsequent cases on the meaning of ‘common-law partner’ or unmarried spouse as a method of deriving evidence about the texture of the lives lived by adults in personal relationships. From that evidence, I seek to contribute to the social history of the margins of conjugal relationships between adult members in a post-legal-equality world in Canada. The project of this chapter is not to be prescriptive about how Canada’s tax legislation should be changed. Rather, it is …
The Supreme Court's 2012 Tax Cases: Formalism Trumps Pragmatism And Good Sense, William Neil Brooks, Kim Brooks
The Supreme Court's 2012 Tax Cases: Formalism Trumps Pragmatism And Good Sense, William Neil Brooks, Kim Brooks
Articles, Book Chapters, & Popular Press
The Supreme Court of Canada released decisions in four cases in the 2012 year. We argue that each illustrates the Court's formalistic approach to interpreting tax legislation. Each of the following four cases is evaluated in turn. Canada v Craig relates to the circumstances under which a taxpayer can offset losses incurred in a farming business against income earned from a completely different source. Fundy Settlement v Canada required determining the residency of a trust for tax purposes. Canada v GlaxoSmithKline Inc. focused on the circumstances to be taken into account in determining an arm's-length price in the transfer pricing …
Up In The Air Over Taxing Frequent Flyer Benefits: The American, Canadian, And Australian Experiences, Lawrence A. Zelenak
Up In The Air Over Taxing Frequent Flyer Benefits: The American, Canadian, And Australian Experiences, Lawrence A. Zelenak
Faculty Scholarship
No abstract provided.