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Doma Implications For Employee Benefit Plans: Round 3, 150 Tax Notes 101 (2016), Kathryn Kennedy Jan 2016

Doma Implications For Employee Benefit Plans: Round 3, 150 Tax Notes 101 (2016), Kathryn Kennedy

Kathryn J. Kennedy

This article is the third in a series on the implications for employee benefit plans of the Supreme Court’s decisions on the constitutionality of the Defense of Marriage Act (DOMA) and state bans on same-sex marriage. In this article, Kennedy highlights the effect Obergefell v. Hodges will have on employee benefit plans.


2003 Federal Tax Update, Samuel Donaldson Nov 2015

2003 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


United States International Taxation, Allison Christians, Samuel Donaldson, Phillip Postlewaite Nov 2015

United States International Taxation, Allison Christians, Samuel Donaldson, Phillip Postlewaite

Samuel A. Donaldson

No abstract provided.


Basic Federal And State Tax Relevant To Estate Planning, Samuel Donaldson, Karen Boxx Nov 2015

Basic Federal And State Tax Relevant To Estate Planning, Samuel Donaldson, Karen Boxx

Samuel A. Donaldson

No abstract provided.


2010 Federal Tax Update, Samuel Donaldson Nov 2015

2010 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

This update explains several developments in the substantive federal income, estate and gift tax laws affecting individual taxpayers and small businesses. It contains summaries of significant cases, rulings, regulations, legislation and other matters from August, 2009, through September, 2010. This update generally does not discuss developments in the areas of qualified plans or the taxation of business entities (except to a very limited extent).


2008 Federal Tax Update, Samuel Donaldson Nov 2015

2008 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

This update explains several developments in the substantive federal income, estate and gift tax laws affecting individual taxpayers and small businesses. It contains summaries of significant cases, rulings, regulations, legislation and other matters from August, 2007, through August, 2008. This update generally does not discuss developments in the areas of qualified plans or the taxation of business entities (except to a very limited extent).


2007 Federal Tax Update, Samuel Donaldson Nov 2015

2007 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


Super-Recognition And The Return-To-Sender Exception: The Federal Income Tax Problems Of Liquidating The Family Limited Partnership, Samuel Donaldson Nov 2015

Super-Recognition And The Return-To-Sender Exception: The Federal Income Tax Problems Of Liquidating The Family Limited Partnership, Samuel Donaldson

Samuel A. Donaldson

This article discusses three income tax rules that can cause partners to recognize gain for federal income tax purposes upon the liquidation of a family limited partnership: §§ 704(c)(1)(B), 731(c), and 737. From a policy perspective, the application of these rules to traditional family limited partnerships creates two problems. These problems are illustrated through the use of a hypothetical case study. The first problem (which arises where the partnership holds loss property) is that of super-recognition, where a partner recognizes more gain from the liquidation than he or she would recognize upon a sale of his or her partnership interest. …


2009 Federal Tax Update, Samuel Donaldson Nov 2015

2009 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

This paper examines significant developments in the federal income, gift, and estate taxation of individuals and small businesses from August, 2008, through August, 2009. It covers important cases, rulings, regulations, and legislation during this period. This paper generally does not address developments in the areas of qualified plans or the taxation of C corporations (except to limited extents).


An Introduction To Federal Wealth Transfer Tax, Samuel Donaldson Nov 2015

An Introduction To Federal Wealth Transfer Tax, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


2004 Federal Tax Update, Samuel Donaldson Nov 2015

2004 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


2006 Federal Tax Update, Samuel Donaldson Nov 2015

2006 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

This update explains several developments in the federal income, estate and gift taxes affecting individual taxpayers and small businesses. It contains summaries of significant cases, rulings, regulations, legislation and other matters from August, 2005, through September, 2006. This update generally does not discuss developments in the areas of qualified plans or the taxation of business entities (except to very limited extents).


2002 Federal Tax Update, Samuel Donaldson Nov 2015

2002 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


2005 Federal Tax Update, Samuel Donaldson Nov 2015

2005 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


Federal Wealth Transfer Taxes, Kevin Yamamoto, Samuel Donaldson Nov 2015

Federal Wealth Transfer Taxes, Kevin Yamamoto, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


United States International Taxation: Cases, Materials, And Problems, Allison Christians, Samuel Donaldson, Phillip Postlewaite Nov 2015

United States International Taxation: Cases, Materials, And Problems, Allison Christians, Samuel Donaldson, Phillip Postlewaite

Samuel A. Donaldson

No abstract provided.


2011 Federal Tax Update, Samuel Donaldson Nov 2015

2011 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

This update explains several developments in the substantive federal income, estate and gift tax laws affecting individual taxpayers and small businesses. It contains summaries of significant cases, rulings, regulations, legislation and other matters from August, 2010, through August, 2011. This update generally does not discuss developments in the areas of qualified plans or the taxation of business entities (except to a very limited extent).


Acing Federal Income Tax, Samuel Donaldson Nov 2015

Acing Federal Income Tax, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


Federal Income Taxation Of Individuals: Cases, Problems & Materials, Samuel Donaldson Nov 2015

Federal Income Taxation Of Individuals: Cases, Problems & Materials, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


Employee Compensation And Related Expenses, Samuel Donaldson Nov 2015

Employee Compensation And Related Expenses, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


2000 Federal Tax Update, Samuel Donaldson Nov 2015

2000 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


2001 Federal Tax Update, Samuel Donaldson Nov 2015

2001 Federal Tax Update, Samuel Donaldson

Samuel A. Donaldson

No abstract provided.


Notable Employee Benefits Articles Of 2012, 139 Tax Notes 656 (2013), Kathryn Kennedy Jun 2015

Notable Employee Benefits Articles Of 2012, 139 Tax Notes 656 (2013), Kathryn Kennedy

Kathryn J. Kennedy

No abstract provided.


The United States Tax Court - A Court For All Parties, T. Fogg Dec 2014

The United States Tax Court - A Court For All Parties, T. Fogg

T. Keith Fogg

This article seeks to explain the role of the Tax Court both within the system of taxation and the system of tribunals of the United States. To provide this explanation, the article will address several specific areas: 1) the mission of the Court; 2) the placement of the Court within the judicial system and the scope of its jurisdiction; 3) selection of judicial officers of the Court; 4) the internal organization of the Court and its opinions; 5) access to the Court; 6) policy issues facing the Court; and 7) interaction between the Court and the public outside the courtroom. …


The Federal Income Taxation Of Corporations, Partnerships, Limited Liability Companies, And Their Owners, 4th Ed., Jeffrey Kwall May 2013

The Federal Income Taxation Of Corporations, Partnerships, Limited Liability Companies, And Their Owners, 4th Ed., Jeffrey Kwall

Jeffrey L. Kwall

No abstract provided.


Federal Income Taxation Of Corporations, Partnerships, Limited Liability Companies And Their Owners, 3d Ed., Jeffrey Kwall May 2013

Federal Income Taxation Of Corporations, Partnerships, Limited Liability Companies And Their Owners, 3d Ed., Jeffrey Kwall

Jeffrey L. Kwall

No abstract provided.


Taxing Social Enterprise, Lloyd Hitoshi Mayer, Joseph R. Ganahl Dec 2012

Taxing Social Enterprise, Lloyd Hitoshi Mayer, Joseph R. Ganahl

Lloyd Hitoshi Mayer

The fairly strict divide in the United States between for-profit and nonprofit forms presents a quandary for many entrepreneurs who want to combine doing good with doing well. On the one hand, for-profits offer great flexibility and access to capital and so attract entrepreneurs who would like to take advantage of the ability of for-profits to scale up rapidly to meet growing demand. At the same time, however, for-profit forms also limit entrepreneurs’ ability to engage in philanthropy, due to the fiduciary duties managers owe to the equity holders. On the other hand, nonprofits offer their founders the freedom to …


Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault Dec 2012

Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault

Hugh J. Ault

No abstract provided.


Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault Sep 2012

Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault

Hugh J. Ault

No abstract provided.


U.S. Taxes Corporate Income At Comparatively Low Rate, Andrew Pike Mar 2012

U.S. Taxes Corporate Income At Comparatively Low Rate, Andrew Pike

Andrew Pike

This article asserts that the United States does not subject corporate profits to a relatively high nominal rate of taxation. In support of this assertion, the article analyzes the VAT, and concludes that the VAT incorporates a tax on corporate profits. The portion of the VAT that taxes corporate profit is comparable to, and at least as burdensome as, the current U.S. corporate income tax. The article concludes that the accepted wisdom that the United States imposes an exceptionally high nominal rate of tax (compared to the nominal rates of taxation imposed in other OECD countries) on corporate profits is …