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Full-Text Articles in Law
Moore V. United States: The U.S. Supreme Court’S Impending Revisiting Of The Definition Of “Income”, Beckett Cantley, Geoffrey Dietrich
Moore V. United States: The U.S. Supreme Court’S Impending Revisiting Of The Definition Of “Income”, Beckett Cantley, Geoffrey Dietrich
University of Miami Business Law Review
The passing of the Tax Cuts and Jobs Act (“TCJA”) in December 2017 made significant changes that affect both domestic and international businesses income taxes. One of the most notable changes involves the Internal Revenue Code (“IRC”) section 965 transition tax on foreign earnings of foreign subsidiaries of U.S. companies, which deems those earnings to be repatriated. Effectively, this transition tax disregards the realization element thought by some to be a U.S. Constitutional requirement. As such, questions have arisen in the courts regarding the constitutionality of these laws. The most noteworthy case of Moore v. United States has found its …
With Coronavirus Ravaging The Economy, Congress Shows Highest Tax Priorities: An Exploration Of The Provisions In The Cares Act And Beyond, Paul Nylen, Brian Huels, Shane Wheeler
With Coronavirus Ravaging The Economy, Congress Shows Highest Tax Priorities: An Exploration Of The Provisions In The Cares Act And Beyond, Paul Nylen, Brian Huels, Shane Wheeler
University of Miami Business Law Review
The virus known as SARS–CoV–21 (Coronavirus) swept over the United States in ways that no other crisis has affected modern society. While the Spanish Flu of 1918 has often been cited for its pandemic similarities to the Coronavirus, from an economic standpoint the attacks of September 11, 2001, and the Great Recession of 2008 are perhaps the Coronavirus’s best analogy for the modern economic carnage that has occurred. In those previous events, Congress responded with sweeping legislation like Dodd–Frank and the Patriot Act. With the Coronavirus, Congress responded with the CARES Act. Within the CARES Act are historical changes to …
United States -- Tax Treatment For "Foreign Sales Corporations" Wto Doc. Wt/Ds108/Ab/R, Stanley I. Langbein
United States -- Tax Treatment For "Foreign Sales Corporations" Wto Doc. Wt/Ds108/Ab/R, Stanley I. Langbein
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