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Articles 1 - 30 of 47
Full-Text Articles in Law
Real Estate Tax Shelters - Historical Structures, Rehabilitated Structures, Low-Income Rental Housing, Condominium Or Cooperative Housing Conversion Tax Problems And Acrs Issues, Thomas R. Frantz
William & Mary Annual Tax Conference
No abstract provided.
The Debt-Equity Regulations (Section 385), Felix B. Laughlin
The Debt-Equity Regulations (Section 385), Felix B. Laughlin
William & Mary Annual Tax Conference
No abstract provided.
Compliance Provisions Of Tax Equity And Fiscal Responsibility Act (Tefra), Charles Roddy
Compliance Provisions Of Tax Equity And Fiscal Responsibility Act (Tefra), Charles Roddy
William & Mary Annual Tax Conference
No abstract provided.
The Impact Of Tefra On Employee Benefits, Louis A. Mezzullo
The Impact Of Tefra On Employee Benefits, Louis A. Mezzullo
William & Mary Annual Tax Conference
No abstract provided.
Planning For Disadvantaged Corporations, Paul Broderick
Planning For Disadvantaged Corporations, Paul Broderick
William & Mary Annual Tax Conference
No abstract provided.
The Future Of Personal Service Corporations: Is There Life After Tefra?, Converse Murdoch
The Future Of Personal Service Corporations: Is There Life After Tefra?, Converse Murdoch
William & Mary Annual Tax Conference
No abstract provided.
Tefra: Purchase And Sale Of A Corporate Business, Martin D. Ginsburg
Tefra: Purchase And Sale Of A Corporate Business, Martin D. Ginsburg
William & Mary Annual Tax Conference
No abstract provided.
International Tax Evasion And Tax Fraud: Typical Schemes And The Legal Issues Raised By Their Detection And Prosecution, Hugh Spall
University of Miami Inter-American Law Review
No abstract provided.
Analysis Of Legislation Enacting Conformity To Selected Items Of The Federal Economic Recovery Tax Act Of 1981, Assembly Revenue And Taxation Committee
Analysis Of Legislation Enacting Conformity To Selected Items Of The Federal Economic Recovery Tax Act Of 1981, Assembly Revenue And Taxation Committee
California Assembly
AB 2595 (Deddeh), Chapter 1558 of 1982
AB 2516 (Sher), Chapter 1525 of 1982
AB 3194 (lmbrecht), Chapter 1559 of 1982
SB 1326 (Alquist), Chapter 327 of 1982
SB 11 (Maddy), Chapter 1604 of 1982
Federal Preemption Of State Authority To Tax Non-Indian Mineral Development On Indian Lands, S. David Colton
Federal Preemption Of State Authority To Tax Non-Indian Mineral Development On Indian Lands, S. David Colton
BYU Law Review
No abstract provided.
State Income Taxation Of Multijurisdictional Corporations, Part Ii: Reflections On Asarco And Woolworth, Walter Hellerstein
State Income Taxation Of Multijurisdictional Corporations, Part Ii: Reflections On Asarco And Woolworth, Walter Hellerstein
Scholarly Works
The first part of this Article, State Income Taxation of Multiurisdictional Corporations: Reflections on Mobil, Exxon, and H A 5076, did not contemplate a sequel. The Supreme Court's decisions last term in two state corporate income tax cases, however, created an irresistible opportunity to write one. The Court's opinions in ASARC0 and Woolworth picked up where its opinions in Mobil and Exxon left off. Yet the direction taken by these more recent decisions veers sharply from the course ostensibly set by their predecessors. This Article will consider the Court's latest pronouncements in this area in a continuing if quixotic effort …
State Income Taxation Of Multijurisdictional Corporations, Part Ii: Reflections On Asarco And Woolworth, Walter Hellerstein
State Income Taxation Of Multijurisdictional Corporations, Part Ii: Reflections On Asarco And Woolworth, Walter Hellerstein
Scholarly Works
The first part of this Article, "State Income Taxation of Multijurisdictional Corporations: Reflections on Mobil, Exxon, and H.R. 5076" [79 Mich. L. Rev. 113], did not contemplate a sequel. The Supreme Court's decisions last term in two state corporate income tax cases, however, created an irresistible opportunity to write one. The Court's opinions in ASARCO and Woolworth picked up where its opinions in Mobil and Exxon left off. Yet the direction taken by these more recent decisions veers sharply from the course ostensibly set by their predecessors. This Article will consider the Court's latest pronouncements in this area in a …
United States V. Rylander, Lewis F. Powell Jr.
United States V. Rylander, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
The Taxation Of Reinvested Corporate Earnings, Richard L. Doernberg
The Taxation Of Reinvested Corporate Earnings, Richard L. Doernberg
William & Mary Law Review
No abstract provided.
The Bad Blood Factor And 302 Redemptions: A Retrospective Examination And Analysis, Joseph J. Miller
The Bad Blood Factor And 302 Redemptions: A Retrospective Examination And Analysis, Joseph J. Miller
West Virginia Law Review
No abstract provided.
Standing To Challenge The Tax-Exempt Status Of Racially Discriminatory Private Schools: Wright V. Regan, Jamie D. Scott
Standing To Challenge The Tax-Exempt Status Of Racially Discriminatory Private Schools: Wright V. Regan, Jamie D. Scott
BYU Law Review
No abstract provided.
Commerce Clause V. Coal Severance Taxation, Wray Voegelin
Commerce Clause V. Coal Severance Taxation, Wray Voegelin
West Virginia Law Review
No abstract provided.
Reflections On Commonwealth Edison Co. V. Montana, Mike Mcgrath, Walter Hellerstein
Reflections On Commonwealth Edison Co. V. Montana, Mike Mcgrath, Walter Hellerstein
Scholarly Works
On the final day of its 1980-81 term, the United States Supreme Court handed down its long-awaited decision in Commonwealth Edison Co. v. Montana, which sustained Montana's coal severance tax over commerce and supremacy clause objections. In a six-to-three decision, the Court upheld the right of the states to set their own tax rates without fear of judicial interference. The Court's conclusion was rooted in its recognition that the determination of the rate or amount of a state tax is fundamentally a political question, which "must be resolved through the political process . . . by state legislatures in …
Federal Limitations On State And Local Taxation, William R. Anderson
Federal Limitations On State And Local Taxation, William R. Anderson
Vanderbilt Law Review
Federal Limitations on State and Local Taxation presents a central question about how usefully and how legitimately courts have dealt with the issues of state taxing powers. The United States Supreme Court has assumed a role as the principal architect of this component of federalism. State legislatures and tax officials have, of course, played roles, but they have always operated under the shadow of judicial doctrine. While Congress has not been wholly inactive, its role has been derivative, interstitial, and hesitant. Perhaps Congress' fact-finding role has been larger than its legislative role.'
Survey Of Developments In The Fourth Circuit: 1981
Survey Of Developments In The Fourth Circuit: 1981
West Virginia Law Review
No abstract provided.
Foreign Illegality: No Absolute Bar To Enforcement Of Internal Revenue Service Summons, Carol S. Goldstein
Foreign Illegality: No Absolute Bar To Enforcement Of Internal Revenue Service Summons, Carol S. Goldstein
University of Miami Inter-American Law Review
No abstract provided.
The Tax Benefit Of Bliss, Alan L. Feld
The Tax Benefit Of Bliss, Alan L. Feld
Faculty Scholarship
In recent years the Supreme Court has limited its substantive decisions in federal income tax matters.I For the most part, the handful of tax cases it has considered each year deal with collection, liens, or other issues peripheral to doctrinal development in the tax area.2 The Court's recent decision in Diedrich v. Commissioner,3 however, dealt with a realization question involving net gifts; and its grant of certiorari consolidating the cases of Bliss Dairy, Inc. v. United States and Hillsboro National Bank v. Commissioner4 promises a continuing interest in substantive tax law. Bliss Dairy will enable the …
A Decision Model For Lease Parties In Sale-Leasebacks Of Real Estate, Nancy E. Shurtz
A Decision Model For Lease Parties In Sale-Leasebacks Of Real Estate, Nancy E. Shurtz
William & Mary Law Review
No abstract provided.
A New Political Economy?, Susan Rose-Ackerman
A New Political Economy?, Susan Rose-Ackerman
Michigan Law Review
A Review of The Power to Tax: Analytical Foundations of a Fiscal Constitution by Geoffrey Brennan and James Buchanan
Federal Tax Concepts As A Guide For State Apportionment Of Dividends, Richard Pomp, Rebecca S. Rudnick
Federal Tax Concepts As A Guide For State Apportionment Of Dividends, Richard Pomp, Rebecca S. Rudnick
Faculty Articles and Papers
In ASARCO, Inc. v. Idaho State Tax Commission, the Supreme Court rejected Idaho’s definition of income, and limited the apportionability of dividends, interest, and capital gains. The Court held that a unitary business relationship did not exist between ASARCO and the dividend payors, but did not address whether such a relationship was a sufficient precondition or a necessary one.
This article addresses two federal tax doctrines that may provide insight into state taxation of dividends: (1) the “effectively connected” doctrine, and (2) the Corn Products doctrine. The article first provides a detailed examination of the facts in ASARCO, and discusses …
Foreign Investors Real Property Tax Act: Historical Perspective And Critical Evaluation, William D. Metzger
Foreign Investors Real Property Tax Act: Historical Perspective And Critical Evaluation, William D. Metzger
Faculty Scholarship
This Article first discusses the United States tax treatment of foreigners generally and the pre-Foreign Investors Real Property Tax Act withholding and taxation scheme with respect to foreign investment in United States real estate. Then follows a discussion of the several ways in which foreign investors were, before the Act, able to avoid tax on the disposition of United States real estate and a critical evaluation of the Act's response to those avoidance methods. Finally, a discussion of the Act's enforcement provisions and a general discussion of withholding of tax on nonresidents is provided.
Kentucky Law Survey: Taxation, Frederick W. Whiteside
Kentucky Law Survey: Taxation, Frederick W. Whiteside
Kentucky Law Journal
No abstract provided.
Fair Market Value In The Tax Law: Replacement Value Or Liquidation Value, Daniel S. Goldberg
Fair Market Value In The Tax Law: Replacement Value Or Liquidation Value, Daniel S. Goldberg
Faculty Scholarship
No abstract provided.
Special U.S. Rules Directly Affecting Foreign Investment, C. Tanner Rose Jr.
Special U.S. Rules Directly Affecting Foreign Investment, C. Tanner Rose Jr.
Penn State International Law Review
The purpose of this article is to provide a list of special U.S. rules which guide domestic attorneys in counseling foreign investors on tax and finance consequences of their transactions in the United States. A firm grasp of these rules, as a starting point, enables an attorney to formulate proper suggestions to foreign clients in acquiring property and conducting business without being subject to excessive tax consequences.