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Full-Text Articles in Law
Rendering Unto Caesar Or Electioneering For Caesar--Loss Of Church Tax Exemption For Participation In Electoral Politics, Alan L. Feld
Rendering Unto Caesar Or Electioneering For Caesar--Loss Of Church Tax Exemption For Participation In Electoral Politics, Alan L. Feld
Faculty Scholarship
The restriction on church participation in political campaigns contained in the Internal Revenue Code operates uneasily. It appears to serve the useful purpose of separating the spheres of religion and electoral politics. But the separation often is only apparent, as churches in practice signal support for a particular candidate in a variety of rays that historically have not cost them their exemptions. Although the limited enforcement by the Internal Revenue Service has reflected the sensitive nature of the First Amendment values present, the federal government should provide more formal elaboration by statute or regulation. Focus on the use of funds …
The Proposed Federal Taxation Of Frequent Flyer Miles Received From Employers: Good Tax Policy But Bad Politics, Dominic L. Daher
The Proposed Federal Taxation Of Frequent Flyer Miles Received From Employers: Good Tax Policy But Bad Politics, Dominic L. Daher
Akron Tax Journal
The purpose of this article is to dissect the plausibility of taxing frequent flyer miles that were earned by employees on employer-paid travel and later used for personal travel. The first issue for resolution is whether the accrual and utilization of frequent flyer miles earned by an employee while on company-paid travel constitutes compensation for services, and hence gross income, within the meaning of I.R.C. § 61(a)(1). The second issue for resolution is whether the accrual and utilization of frequent flyer miles earned by an employee while on company-paid travel constitutes a taxable fringe benefit, and hence gross income, within …
Dominion Resources: Powering Section 1341 Toward Equity?, Edward J. Schnee
Dominion Resources: Powering Section 1341 Toward Equity?, Edward J. Schnee
Akron Tax Journal
Administrative concerns occasionally override other aspects of tax policy. One example is the imposition of an annual reporting cycle which leads taxpayers to make assumptions about future events so that items can be reported on regularly scheduled returns. This can result in reporting items as income that are not actually earned by the taxpayer. For example, under the claim of right doctrine, created because of the annual reporting requirement, taxpayers must report certain receipts as income even though they are later required to return these amounts to the payor. In most cases they are permitted a deduction in the year …
Concerto For Piano Vs. Orchestra: Can Tax And Financial Accounting Harmonize On Hedges?, John J. Ensminger
Concerto For Piano Vs. Orchestra: Can Tax And Financial Accounting Harmonize On Hedges?, John J. Ensminger
Akron Tax Journal
The preference for fair value accounting, for marking items to market for financial reporting or tax purposes, has been particularly strong in the last decade, and has become almost doctrine among accounting standards setters as the preferred method of accounting for financial instruments. Though a similar trend can be documented for tax accounting, the longstanding preference for correlating tax liability with realization events continues to prevent consistency. Also preventing consistency are the myriad difficulties in distinguishing capital gain from ordinary income (where embedded derivatives seem to make the result almost arbitrary), those equally subtle difficulties in distinguishing debt from equity …
International Tax Competition: An Efficient Or Inefficient Phenomenon?, Mitchell B. Weiss
International Tax Competition: An Efficient Or Inefficient Phenomenon?, Mitchell B. Weiss
Akron Tax Journal
This Article examines the legal and economic implications of this globalization phenomenon. Part I discusses the allocative effect an income tax system has on a particular country's resources. This first part, while focusing only on domestic tax policy, is intended to throw some light on the international issues that are the central focus of this article. So with this background in mind, Part II turns to the international scene, analyzing the efficiency effect international integration is having on the world's income tax systems in general and the U.S.'s income tax system in particular. Finally, Part III considers what the Organisation …
Federal Tax Collection Controversies In The Era Of Drye, Steve R. Johnson
Federal Tax Collection Controversies In The Era Of Drye, Steve R. Johnson
Articles by Maurer Faculty
By "tax collection controversies," I mean cases in which it has been established that the taxpayer owes additional taxes, those taxes remain unpaid, and the IRS is attempting to enforce collection out of the taxpayer's assets. Such cases are numerous and involve attorneys in general legal practice as well as tax specialists. For example, the taxpayer may be your client for non-tax matters, and may expect you to handle her tax collection controversy as well. Or, your client may not be the taxpayer herself, but instead someone who co-owns property with the taxpayer. Your client expects you to make sure …
Are There Procedural Deficiencies In Tax Fraud Cases? A Reply To Professor Schoenfeld, Leandra Lederman
Are There Procedural Deficiencies In Tax Fraud Cases? A Reply To Professor Schoenfeld, Leandra Lederman
Articles by Maurer Faculty
No abstract provided.
Random Thoughts On Applying Judicial Doctrines To Interpret The Internal Revenue Code, Martin J. Mcmahon Jr.
Random Thoughts On Applying Judicial Doctrines To Interpret The Internal Revenue Code, Martin J. Mcmahon Jr.
UF Law Faculty Publications
From the symposium "Business Purpose, Economic Substance, and Corporate Tax Shelters" .