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Full-Text Articles in Law

The Strange And Curious Tax Treatment Of Investment Expenses, Jay A. Soled, Mallory A. Morris May 2022

The Strange And Curious Tax Treatment Of Investment Expenses, Jay A. Soled, Mallory A. Morris

Villanova Law Review

No abstract provided.


Workplace Transformation And Its Tax Compliance Implications, Jay A. Soled Sep 2021

Workplace Transformation And Its Tax Compliance Implications, Jay A. Soled

Villanova Law Review

No abstract provided.


Puff, Puff, Tax: Internal Revenue Code Section 280e Penalizes State-Sanctioned Marijuana Companies And Undermines The Ability-To-Pay Principle, Joseph E. Thomas Jul 2021

Puff, Puff, Tax: Internal Revenue Code Section 280e Penalizes State-Sanctioned Marijuana Companies And Undermines The Ability-To-Pay Principle, Joseph E. Thomas

Villanova Law Review

No abstract provided.


Social Justice And The Low-Income Taxpayer, W. Edward Afield Sep 2019

Social Justice And The Low-Income Taxpayer, W. Edward Afield

Villanova Law Review

No abstract provided.


"Works For Me": What's Next For Pennsylvania Corporate Tax Liabilities After Nextel Communications Of The Mid-Atlantic V. Commonwealth, Riley Bauer Oct 2018

"Works For Me": What's Next For Pennsylvania Corporate Tax Liabilities After Nextel Communications Of The Mid-Atlantic V. Commonwealth, Riley Bauer

Villanova Law Review

No abstract provided.


Martin Luther King, Jr. Lecture - "Skin In The Tax Game": Invisible Taxpayers? Invisible Citizens?, Mildred Wigfall Robinson Sep 2014

Martin Luther King, Jr. Lecture - "Skin In The Tax Game": Invisible Taxpayers? Invisible Citizens?, Mildred Wigfall Robinson

Villanova Law Review

No abstract provided.


Not Just Whistling Dixie: The Case For Tax Whistleblowers In The States, Dennis J. Ventry Jr. Aug 2014

Not Just Whistling Dixie: The Case For Tax Whistleblowers In The States, Dennis J. Ventry Jr.

Villanova Law Review

No abstract provided.


Tax Evaded In The Federal Tax Crimes Sentencing Process And Beyond, John A. Townsend Aug 2014

Tax Evaded In The Federal Tax Crimes Sentencing Process And Beyond, John A. Townsend

Villanova Law Review

No abstract provided.


Clash For Cash: The Conflict Over Tax Whistleblower Contracts, Jeremiah Coder Aug 2014

Clash For Cash: The Conflict Over Tax Whistleblower Contracts, Jeremiah Coder

Villanova Law Review

No abstract provided.


Loving V. Irs: The Treasury Department's Authority To Regulate Tax Return Preparation Conduct Of Commercial Return Preparers, Lawrence B. Gibbs Aug 2014

Loving V. Irs: The Treasury Department's Authority To Regulate Tax Return Preparation Conduct Of Commercial Return Preparers, Lawrence B. Gibbs

Villanova Law Review

No abstract provided.


Loving And Legitimacy: Irs Regulation Of Tax Return Preparation, Steve R. Johnson Aug 2014

Loving And Legitimacy: Irs Regulation Of Tax Return Preparation, Steve R. Johnson

Villanova Law Review

No abstract provided.


Sentencing In Tax Cases After Booker: Striking The Right Balance Between Uniformity And Discretion, Scott A. Schumacher Aug 2014

Sentencing In Tax Cases After Booker: Striking The Right Balance Between Uniformity And Discretion, Scott A. Schumacher

Villanova Law Review

No abstract provided.


A Preference For Deference: The Benefits Of The First Circuit's Customized Standard Of Review For Collection Due Process Appeals In Dalton V. Commissioner, Adam M. Cole Mar 2013

A Preference For Deference: The Benefits Of The First Circuit's Customized Standard Of Review For Collection Due Process Appeals In Dalton V. Commissioner, Adam M. Cole

Villanova Law Review

No abstract provided.


Symposium Introduction: Offshore Accounts, Corporate Income Shifting, And Executive Compensation, Leslie Book Jan 2012

Symposium Introduction: Offshore Accounts, Corporate Income Shifting, And Executive Compensation, Leslie Book

Villanova Law Review

No abstract provided.


Some Suggestions For Tax Reform, Michael C. Durst Jan 2012

Some Suggestions For Tax Reform, Michael C. Durst

Villanova Law Review

No abstract provided.


Offshore Accounts: Insider's Summary Of Fatca And Its Potential Future, J. Richard Harvey Jr. Jan 2012

Offshore Accounts: Insider's Summary Of Fatca And Its Potential Future, J. Richard Harvey Jr.

Villanova Law Review

No abstract provided.


Sniping Down Ignorance Claims: The Third Circuit In United States V. Stadtmauer Upholds Willful Blindness Instructions In Criminal Tax Cases, Rachel Zuraw Jan 2012

Sniping Down Ignorance Claims: The Third Circuit In United States V. Stadtmauer Upholds Willful Blindness Instructions In Criminal Tax Cases, Rachel Zuraw

Villanova Law Review

The article presents information on the criminal tax cases and the claims of ignorance of relevant legal duties or misunderstanding. The complexities in the tax code of the U.S., interpretation of willful blindness by the U.S. courts and the standard for conviction are discussed. The non-tax fraud case law, strict interpretation of conscious avoidance in tax statutes and the duty implicitly imposed on taxpayers are also discussed with reference to the trial of Cheek v. United States.


Is United States Corporate Tax Policy Outsourcing America - A Critical Analysis Of The Proposed Tax Holiday For Trapped Cfc Earnings, Robert Bloink Jan 2012

Is United States Corporate Tax Policy Outsourcing America - A Critical Analysis Of The Proposed Tax Holiday For Trapped Cfc Earnings, Robert Bloink

Villanova Law Review

THE debate about how best to reform U.S. corporate tax policy has focused almost exclusively on making U.S. corporations more competitive globally. But the debate often glosses over tax policy's effect on the ultimate beneficiaries of corporate success and failure—U.S. corporate stakeholders. The assumption often has been that healthy, competitive U.S. corporations equal healthy stakeholders—including shareholders, employees, and the U.S. populace as a whole. However, recent economic research has brought the assumption of "trickle down" success into question. This Article suggests an alternate path focused on enhancing the competitiveness of U.S. MNCs in the global economy while enhancing the welfare …


Go West: How The Irs Should Foster Innovation In Its Agents, T. Keith Fogg Jan 2012

Go West: How The Irs Should Foster Innovation In Its Agents, T. Keith Fogg

Villanova Law Review

No abstract provided.


The Use Of Voluntary Disclosure Initiatives In The Battle Against Offshore Tax Evasion, Leandra Lederman Jan 2012

The Use Of Voluntary Disclosure Initiatives In The Battle Against Offshore Tax Evasion, Leandra Lederman

Villanova Law Review

No abstract provided.


Ask For Help, Uncle Sam: The Future Of Global Tax Reporting, Susan C. Morse Jan 2012

Ask For Help, Uncle Sam: The Future Of Global Tax Reporting, Susan C. Morse

Villanova Law Review

No abstract provided.


The Role Of International Law And Practice In Addressing International Tax Issues In The Global Era, Charles H. Gustafson Jan 2011

The Role Of International Law And Practice In Addressing International Tax Issues In The Global Era, Charles H. Gustafson

Villanova Law Review

The article discusses the role of international law and practice in deciphering complex international tax policy and administration issues as of July 2011. An August 2009 deal between the U.S. and Switzerland, known as the U.S.-Swiss Agreement, is also mentioned. The international law of jurisdiction is examined as it relates to the issue of double taxation.


One Case To Rule Them All: The Ninth Circuit In Bakersfield Applies Colony To Deny The Irs An Extended Statute Of Limitations In Overstatement Of Basis Cases, Bernard J. Audet Jr. Jan 2010

One Case To Rule Them All: The Ninth Circuit In Bakersfield Applies Colony To Deny The Irs An Extended Statute Of Limitations In Overstatement Of Basis Cases, Bernard J. Audet Jr.

Villanova Law Review

No abstract provided.


Got Milk... Not Today: The Third Circuit Defends First Amendment Rights For Small Dairy Farmers, Jaret N. Gronczewski Jan 2005

Got Milk... Not Today: The Third Circuit Defends First Amendment Rights For Small Dairy Farmers, Jaret N. Gronczewski

Villanova Law Review

No abstract provided.


Innocent Spouses: A Critique Of The New Tax Laws Governing Joint And Several Tax Liability, Lily Kahng Jan 2004

Innocent Spouses: A Critique Of The New Tax Laws Governing Joint And Several Tax Liability, Lily Kahng

Villanova Law Review

No abstract provided.


Taxing Prometheus: How The Corporate Interest Deduction Discourages Innovation And Risk-Taking, Michael S. Knoll Jan 1993

Taxing Prometheus: How The Corporate Interest Deduction Discourages Innovation And Risk-Taking, Michael S. Knoll

Villanova Law Review

No abstract provided.


On Disclaimers: Let's Renounce I.R.C. Section 2518, Joan B. Ellsworth Jan 1993

On Disclaimers: Let's Renounce I.R.C. Section 2518, Joan B. Ellsworth

Villanova Law Review

No abstract provided.


Sheltering Social Policy In The Tax Code: The Low-Income Housing Credit, Tracy A. Kaye Jan 1993

Sheltering Social Policy In The Tax Code: The Low-Income Housing Credit, Tracy A. Kaye

Villanova Law Review

No abstract provided.


Greenmail, Golden Parachutes And The Internal Revenue Code: A Tax Policy Critique Of Sections 280g, 4999 And 5881, Edward A. Zelinsky Jan 1990

Greenmail, Golden Parachutes And The Internal Revenue Code: A Tax Policy Critique Of Sections 280g, 4999 And 5881, Edward A. Zelinsky

Villanova Law Review

No abstract provided.


How Section 469 Redefines The Tax Shelter - And How The Regulations Redefine Section 469, Thomas J. Donnelly Jan 1989

How Section 469 Redefines The Tax Shelter - And How The Regulations Redefine Section 469, Thomas J. Donnelly

Villanova Law Review

No abstract provided.