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Full-Text Articles in Law

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.


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.


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.


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.


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

Some Suggestions For Tax Reform, Michael C. Durst

Villanova Law Review

No abstract provided.