Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Taxation (8)
- Income Tax (3)
- International Taxation (3)
- Income tax (2)
- Taxation-Federal Income (2)
-
- AEOI (1)
- Bitnet (1)
- Business organizations (1)
- CRS (1)
- Capital gains (1)
- Commodification of individual identity (1)
- Comparative Income Taxation (1)
- Constitutional Law (1)
- Corporate tax (1)
- Corporations (1)
- Corruption (1)
- Discussion groups (1)
- Distributive Justice (1)
- Estate tax (1)
- FATCA (1)
- Foreign income (1)
- Foreign investors (1)
- IRS (1)
- Integration systems (1)
- Internal Revenue Service (1)
- International income (1)
- International tax law (1)
- International tax research (1)
- International taxation (1)
- Investment Banking (1)
- Publication
- File Type
Articles 1 - 19 of 19
Full-Text Articles in Taxation
Assessment Limits And Timing Of Real Estate Transactions, Sebastien J. Bradley
Assessment Limits And Timing Of Real Estate Transactions, Sebastien J. Bradley
Sebastien J Bradley
How May The United States Leverage Fatca To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments?, William H. Byrnes
How May The United States Leverage Fatca To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments?, William H. Byrnes
William H. Byrnes
A Review And Critique Of Selected Problem Areas From The Tax Reform Act Of 1976, Neil E. Harl, Michael D. Boehlje
A Review And Critique Of Selected Problem Areas From The Tax Reform Act Of 1976, Neil E. Harl, Michael D. Boehlje
Neil E. Harl
Rarely has agriculture enjoyed the attention it received in the Tax Reform Act of 1976. In addition to various provisions narrowing the scope of tax shelter opportunities, Congressional attention was drawn to the federal estate tax concerns that were believed to be unique to agriculture and other small firms. As a result, legislation was enacted providing two new methods for valuing land, an expanded and more attractive installment option or paying the federal estate tax attributable to a qualifying business, a new rule for taxing post-1976 joint tenancies at death,— an opportunity to continue "Section 303" stock redemptions for the …
Agency Activism As A New Way Of Life: Administrative Modification Of The Internal Revenue Code Through Limited Issue Focused Examinations, W Edward Afield
Agency Activism As A New Way Of Life: Administrative Modification Of The Internal Revenue Code Through Limited Issue Focused Examinations, W Edward Afield
W. Edward "Ted" Afield
In the name of increasing efficiency and better utilizing limited resources, the IRS has begun to adopt audit policies that overly favor taxpayers and greatly hinder the IRS’s ability to perform thorough audits. Highlighting this trend is a relatively new audit technique used by the Large to Mid-Size Business Division (LMSB), known as the Limited Issue Focused Examination (LIFE) Process. Under LIFE, the LMSB has attempted to involve taxpayers in the audit process by sharing responsibility for timely completion of the audit and has attempted to streamline the audit by reducing the scope of issues examined and applying materiality thresholds …
The Common Knowledge Of Tax Abuse, Mark P. Gergen
The Common Knowledge Of Tax Abuse, Mark P. Gergen
Mark P. Gergen
No abstract provided.
The Influence Of Tax Law On Securities Innovation In The United States: 1981-1997, Mark P. Gergen, Paula Schmitz
The Influence Of Tax Law On Securities Innovation In The United States: 1981-1997, Mark P. Gergen, Paula Schmitz
Mark P. Gergen
No abstract provided.
Can Wealth Taxes Be Justified, Eric Rakowski
Determining A Partner's Share Of Unrealized Receivables At The Liquidation Of The Partner's Interest, Stephen Utz
Determining A Partner's Share Of Unrealized Receivables At The Liquidation Of The Partner's Interest, Stephen Utz
Stephen Gerard Utz
Partnership law allows partners great freedom to vary the terms on which they share partnership profits from different sources. Partnership tax law, however, seems to presume, for purposes of the collapsible partner rules, that partners will share the revenue from the collection of receivables always in proportion to the value of their partnership interests. This counterfactual presumption exposes both the government and partner/taxpayers to unfortunate consequences. A substance-over-form approach to the attribution of unrealized receivables would certainly be unworkable, because too costly and intrusive to administer. Something between substance-over form and form-over-substance would best implement the policy of Subchapter K …
The Quickly--Evolving Tax Filing Status For Same-Gender Couples, John Treu
The Quickly--Evolving Tax Filing Status For Same-Gender Couples, John Treu
John S. Treu
Discusses the evolving law regarding federal income tax filing status for same-gender couples.
The Death Of The Income Tax: A Progressive Consumption Tax And The Path To Fiscal Reform, Daniel Goldberg
The Death Of The Income Tax: A Progressive Consumption Tax And The Path To Fiscal Reform, Daniel Goldberg
Daniel S. Goldberg
The Death of the Income Tax explains how the current income tax is needlessly complex, contains perverse incentives against saving and investment, fails to use modern technology to ease compliance and collection burdens, and is subject to micromanaging and mismanaging by Congress. Daniel Goldberg proposes that the solution to the problems of the current income tax is completely replacing it with a progressive consumption tax collected electronically at the point of sale.
Introduction, Comparative Income Taxation: A Structured Analysis, Hugh J. Ault, Brian J. Arnold
Introduction, Comparative Income Taxation: A Structured Analysis, Hugh J. Ault, Brian J. Arnold
Hugh J. Ault
This work presents a comparative analysis of some of the structural and design issues which are involved in mature income tax systems. Countries selected for the study are Australia, Canada, France, Germany, Japan, The Netherlands, Sweden, the United Kingdom and the United States. Each of the systems has evolved its own particular set of approaches and principles, outlined in Part One. Ensuing Parts deal with Basic Income Taxation, Taxation of Business Organizations and International Taxation. There is much to learn in the tax field from a comparative analysis of common problems. One need not believe in the existence of a …
Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault
Corporate Integration, Tax Treaties, And The Division Of The International Tax Base: Principles And Practices., Hugh J. Ault
Hugh J. Ault
In this Article, Professor Ault begins with an examination of the evolution of treaty principles for the allocation of and restrictions on international taxing jurisdiction. He then focuses on how economically based principles dealing with the taxation of international income affect treaty policy and presents the basic structural provisions involving the taxation of foreign income and foreign investors that emerge from domestically enacted or proposed integration systems. The technical aspects of the actual treaty practices that have been implemented with respect to integration systems are then related to the theoretical discussion. Professor Ault concludes with an examination of the implications …
The Misuse Of Tax Incentives To Align Management-Shareholder Interests, James R. Repetti
The Misuse Of Tax Incentives To Align Management-Shareholder Interests, James R. Repetti
James R. Repetti
The U.S. tax system contains many provisions which are intended to align management of large publicly traded companies more closely to stockholders. This article shows that many of the tax provisions that have been adopted are of questionable effectiveness because they fail to address the complexities of stockholder-management relations in attempting to motivate management to act in the best interests of stockholders. The article proposes that rather than Congress attempting to identify the best way that it can use the tax system to motivate management, Congress should eliminate tax provisions which subsidize management's inefficiencies in order to encourage stockholders, themselves, …
The Promise Of International Tax Scholarship And Its Implications For Research Design, Theory And Methodology, Diane M. Ring
The Promise Of International Tax Scholarship And Its Implications For Research Design, Theory And Methodology, Diane M. Ring
Diane M. Ring
What should international tax scholars be doing? Over the past two decades, international tax has grown both as a practice area and as a field of study. Scholars have begun devoting significant attention to the development, design, and implementation of international tax law. This activity is accompanied by a reflection on the scholarship and its goals, method and content. A review of modern international tax scholarship reveals that as the field has matured, international tax scholars have increasingly turned to other disciplines, especially social sciences, to draw upon their insights, ideas, and research to improve understanding of international tax policy. …
Democracy, Sovereignty And Tax Competition: The Role Of Tax Sovereignty In Shaping Tax Cooperation, Diane M. Ring
Democracy, Sovereignty And Tax Competition: The Role Of Tax Sovereignty In Shaping Tax Cooperation, Diane M. Ring
Diane M. Ring
This paper considers the question of how sovereignty shapes arguments over the merits of tax competition and how sovereignty influences the design of responses to tax competition. Part I provides a basic overview of sovereignty concepts, in particular their relevance to a nation-state desirous of control over tax policy. Part II defines tax competition, identifies the different kinds of states involved, reviews the emergence of the OECD project to limit harmful tax competition, and traces the EU experience with tax competition. Part III explores the normative grounds for challenging tax competition and the role of sovereignty in shaping and limiting …
E-Tax: Fundamental Tax Reform And The Transition To A Currency-Free Economy, Daniel S. Goldberg
E-Tax: Fundamental Tax Reform And The Transition To A Currency-Free Economy, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
Sit Down And Count The Cost: A Framework For Constitutionally Enforcing The 501(C)(3) Campaign Intervention Ban, Benjamin M. Leff
Sit Down And Count The Cost: A Framework For Constitutionally Enforcing The 501(C)(3) Campaign Intervention Ban, Benjamin M. Leff
Benjamin Leff
Abstract:
Section 501(c)(3) of the Internal Revenue Code prohibits charities from intervening in a political campaign for or against a candidate for public office. The IRS currently interprets the campaign-intervention ban to absolutely prevent charities from communicating their views on candidates, even if such communications are completely financed by non-501(c)(3) affiliates.
This article argues that the current IRS enforcement paradigm is unconstitutional because it exceeds the government interest in preventing tax-deductible donations to be used for campaign-intervention. A constitutional interpretation exists under the current statutory framework, but it would require the IRS to shift its focus exclusively to campaign-intervention-related expenditures. …
Taxing Personhood: Estate Taxes And The Compelled Commodification Of Identity, Ray D. Madoff
Taxing Personhood: Estate Taxes And The Compelled Commodification Of Identity, Ray D. Madoff
Ray D. Madoff
In this Article, Professor Madoff explores the ways in which the blunt tools of the wealth tax, and in particular the estate tax, uses a one-size-fits-all system to impose a tax on all property interests owned at the time of one’s death. Professor Madoff illustrates the ways in which these blunt tools can produce problematic results by examining their application to the right of publicity, a newly recognized property interest. Professor Madoff suggests that the imposition of the estate tax can force the commodification of an individual’s identity, regardless of one’s desire to refrain from marketing their identity, and explores …
Fedtax-L, Raleigh Muns
Fedtax-L, Raleigh Muns
Raleigh Muns