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Anaylyzing Subpart F In Light Of Check-The-Box, Cynthia Ram Sweitzer
Anaylyzing Subpart F In Light Of Check-The-Box, Cynthia Ram Sweitzer
Akron Tax Journal
This article explains the history of the Subpart F compromise and of the CTB regime that beleaguers its application. The paper then evaluates whether Subpart F as an independent system is capable of affecting the policy goals behind its creation. Subsequently, this paper analyzes what is the most prudent and economically sound course of action for healing the U.S. international taxation system. Namely, at issue is whether additional regulation, in the form of a re-vamped Subpart F or a scaled-down CTB, would solve the ailments, or whether the complete revocation of existing policies, such as the U.S. semi-worldwide taxation system …
Challenging The Finality Of Tax Court Judgments: When Is Final Not Really Final?, Stephen C. Gara
Challenging The Finality Of Tax Court Judgments: When Is Final Not Really Final?, Stephen C. Gara
Akron Tax Journal
The present article reviews this statutory finality rule and the development of equitable exceptions to it, particularly the application of the fraud upon the court doctrine. The next section provides an overview of the Tax Court, followed by a discussion of judgment finality and section 7481. Part four discusses the fraud upon the court doctrine and its applicability in reviewing final judgments. The development of other exceptions to section 7481 is analyzed next. The article concludes with an assessment of the current state of the Tax Court's authority to make exceptions to section 7481.
Congress Giveth And Congress Taketh Away: The Slow Death Of The Sesop, Beckett G. Cantley
Congress Giveth And Congress Taketh Away: The Slow Death Of The Sesop, Beckett G. Cantley
Akron Tax Journal
This article discusses in detail each of the S Corp. Employee Stock Ownership Plan (SESOP) skirmishes mentioned above and outlines the practical effect of the outcome of each of them.