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Articles 1 - 11 of 11
Full-Text Articles in Law
Heteronormativity And Federal Tax Policy, Nancy J. Knauer
Heteronormativity And Federal Tax Policy, Nancy J. Knauer
West Virginia Law Review
No abstract provided.
Internal Revenue Code Section 1259: A Legitimate Foundation For Taxing Short Sales Against The Box Or A Mere Makeover?, Simon D. Ulcickas
Internal Revenue Code Section 1259: A Legitimate Foundation For Taxing Short Sales Against The Box Or A Mere Makeover?, Simon D. Ulcickas
William & Mary Law Review
No abstract provided.
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption (Symposium), Evelyn Brody
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption (Symposium), Evelyn Brody
All Faculty Scholarship
No abstract provided.
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption, Evelyn Brody
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption, Evelyn Brody
All Faculty Scholarship
This piece explores the broad financial relationship between the public and the charitable sectors. Tax exemption operates as a peculiar subsidy - offering the greatest benefits to charities carrying on the most profitable activities and owning the most valuable property. Perhaps, then, the property tax and income tax exemption of charities can be explained by a 'sovereign' view of the charitable sector. Resembling the federal tax treatment of state and local governments, exemption for charities respects the independence of the nonprofit sector, and minimizes the involvement of charities in the political process. Unfortunately, the long history of Anglo American philanthropy …
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption, Evelyn Brody
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption, Evelyn Brody
Evelyn Brody
This piece explores the broad financial relationship between the public and the charitable sectors. Tax exemption operates as a peculiar subsidy - offering the greatest benefits to charities carrying on the most profitable activities and owning the most valuable property. Perhaps, then, the property tax and income tax exemption of charities can be explained by a 'sovereign' view of the charitable sector. Resembling the federal tax treatment of state and local governments, exemption for charities respects the independence of the nonprofit sector, and minimizes the involvement of charities in the political process. Unfortunately, the long history of Anglo American philanthropy …
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption (Symposium), Evelyn Brody
Of Sovereignty And Subsidy: Conceptualizing The Charity Tax Exemption (Symposium), Evelyn Brody
Evelyn Brody
No abstract provided.
American Indian Law Meets The Internal Revenue Code: Warbus V. Commissioner, Erik M. Jensen
American Indian Law Meets The Internal Revenue Code: Warbus V. Commissioner, Erik M. Jensen
Faculty Publications
This article examines a 1998 Tax Court decision, Warbus v. Commissioner, that has implications for both American Indian law and federal tax law. Section 7873 of the Internal Revenue Code exempts from taxation amounts derived by American Indian tribal members from fishing-rights related activit[ies] of their tribes. Taxpayer Warbus claimed that discharge of indebtedness income from the foreclosure of his fishing boat qualified for the exclusion; the Tax Court said no. The author argues that Warbus was wrongly decided for two reasons: the court failed to take account of basic principles of American Indian law, and the court misapplied the …
Checkpoints On The Conversion Highway: Some Trouble Spots In The Conversion Of Nonprofit Health Care Organizations To For-Profit Status, James J. Fishman
Checkpoints On The Conversion Highway: Some Trouble Spots In The Conversion Of Nonprofit Health Care Organizations To For-Profit Status, James J. Fishman
Elisabeth Haub School of Law Faculty Publications
This essay does not address the truly important policy issues: whether for-profit healthcare should be allowed or encouraged; how the quality of care compares to nonprofits or what criteria should be used to evaluate the quality of care; or what the impact of these conversions is on the communities they serve. It discusses less significant issues: those of process—how can we shape and control this tidal wave of change so that the public will be served and charitable assets preserved to the maximum extent possible? The focus is upon the valuation of these charitable assets; the appropriate process of conversion; …
Federal Income Taxation: Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation: Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 2000 Supplement: Federal Income Taxation: Cases and Materials, 4th ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 2000; 2003 Supplement: Federal Income Taxation: Cases and Materials, 4th ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 2003
The Oecd's Report On Harmful Tax Competition, Hugh Ault, Joann Weiner
The Oecd's Report On Harmful Tax Competition, Hugh Ault, Joann Weiner
Hugh J. Ault
In response to pressures created by the increasing globalization of the world economy, the OECD has issued a report titled “Harmful Tax Competition: An Emerging Global Issue” that provides an analysis of the phenomenon known as harmful tax competition. The Report identifies factors that characterize tax havens and harmful preferential tax regimes and recommends numerous measures in the areas of domestic legislation, tax treaties, and international cooperation, that countries may pursue to counter harmful tax competition. As part of intensifying international cooperation, the Report recommends that Member countries adopt a set of Guidelines endorsing the “3 R’s:” to refrain, to …
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Hugh J. Ault
No abstract provided.