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Articles 1 - 26 of 26
Full-Text Articles in Law
The Deceptively Disparate Treatment Of Business And Investment Interest Expense Under A Cash-Flow Consumption Tax And A Schanz-Haig-Simons Income Tax, J. Clifton Fleming, Jr.
The Deceptively Disparate Treatment Of Business And Investment Interest Expense Under A Cash-Flow Consumption Tax And A Schanz-Haig-Simons Income Tax, J. Clifton Fleming, Jr.
Faculty Scholarship
No abstract provided.
Recent Federal Income Tax Developments, Ira B. Shepard
Recent Federal Income Tax Developments, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Nonqualified Deferred Compensation Plans And Equity-Based Compensation, Louis A. Mezzullo
Nonqualified Deferred Compensation Plans And Equity-Based Compensation, Louis A. Mezzullo
William & Mary Annual Tax Conference
No abstract provided.
Executive Compensation: Dealing With The New Law And Other Developments, William Dunn
Executive Compensation: Dealing With The New Law And Other Developments, William Dunn
William & Mary Annual Tax Conference
No abstract provided.
Theories Of The Federal Income Tax Exemption For Charities: Thesis, Anithesis, And Synthesis, Rob Atkinson
Theories Of The Federal Income Tax Exemption For Charities: Thesis, Anithesis, And Synthesis, Rob Atkinson
Scholarly Publications
No abstract provided.
Sierra Club V. Commissioner And The Royalty Exemption To The Unrelated Business Income Tax: How Much Activity Is Too Much?, Katherine A. Vanye
Sierra Club V. Commissioner And The Royalty Exemption To The Unrelated Business Income Tax: How Much Activity Is Too Much?, Katherine A. Vanye
Washington Law Review
In Sierra Club v. Commissioner, the Ninth Circuit decided that royalties are payments for the right to use intangible property and are by definition "passive." The court applied this definition and held that Sierra Club's income from renting its mailing list was a royalty payment and thus exempt from taxation. This Note argues that while the court reached the correct conclusion, it did not propose a clear standard to guide future cases. Two alternative approaches could be adopted: (1) ancillary versus significant services; or (2) comparative value of property and services. These alternatives will provide clearer guidelines and enable …
The Deemed Transfer Of Recourse Liabilities Leads To Owen Taxes: What Is Wrong With Form Over Substance?, Christine L. Agnew
The Deemed Transfer Of Recourse Liabilities Leads To Owen Taxes: What Is Wrong With Form Over Substance?, Christine L. Agnew
University of Miami Law Review
No abstract provided.
International Aspects Of Fundamental Tax Restructuring: Practice Or Principle?, Michael J. Graetz
International Aspects Of Fundamental Tax Restructuring: Practice Or Principle?, Michael J. Graetz
University of Miami Law Review
No abstract provided.
The Future Of Capital Export Neutrality: A Comment On Robert Peroni's Path To Progressive Reform Of The U.S. International Tax Rules, Stanley I. Langbein
The Future Of Capital Export Neutrality: A Comment On Robert Peroni's Path To Progressive Reform Of The U.S. International Tax Rules, Stanley I. Langbein
University of Miami Law Review
No abstract provided.
The Definition Of Voting Stock And The Computation Of Voting Power Under Sections 368(C) And 1504(A): Recent Developments And Tax Lore, Stuart G. Lazar
The Definition Of Voting Stock And The Computation Of Voting Power Under Sections 368(C) And 1504(A): Recent Developments And Tax Lore, Stuart G. Lazar
Journal Articles
Although the concepts of "voting stock" and "voting power" are pervasive throughout the Code, until recently, courts, commentators and the Service have devoted minimal energy to demystifying the confusion surrounding the definition of voting stock and even less to expanding upon the methodology of computing voting power. Recent developments, however, may prompt practitioners to take a second look at these terms. While a 1995 decision by the Tax Court adds little to the existing body of authority with respect to the determination of the owner of voting stock, the Service's analysis of the voting power requirement in a 1994 private …
Comments On Professor Peroni's Paper On Reform Of The U.S. International Income Tax Rules, David R. Tillinghast
Comments On Professor Peroni's Paper On Reform Of The U.S. International Income Tax Rules, David R. Tillinghast
University of Miami Law Review
No abstract provided.
Federal Taxation, Ben E. Muraskin, James A. Lawton, Tiffani W. Greene
Federal Taxation, Ben E. Muraskin, James A. Lawton, Tiffani W. Greene
Mercer Law Review
No abstract provided.
Comment: What's On Second?, George Mundstock
Comment: What's On Second?, George Mundstock
University of Miami Law Review
No abstract provided.
Kochanksky V. Commissioner: The Assignment Of Income Doctrine, Community Property Law, And I.R.C. § 1041, Sarah Dods
Kochanksky V. Commissioner: The Assignment Of Income Doctrine, Community Property Law, And I.R.C. § 1041, Sarah Dods
Washington Law Review
In Kochansky v. Commissioner, the Ninth Circuit held that an attorney was fully taxable on a contingent fee he agreed to split with his spouse at divorce, reasoning that the assignment of income doctrine requires that income be taxed to the person who earns it. This Note observes that in applying the assignment doctrine, the Kochansky court erred by failing to determine the extent of the spouse's community property interest in the contingent fee; community property income must be taxed one-half to each spouse, regardless of which spouse earns it, which spouse collects it, and when it is collected. …
Back To The Future: A Path To Progressive Reform Of The U.S. International Income Tax Rules, Robert J. Peroni
Back To The Future: A Path To Progressive Reform Of The U.S. International Income Tax Rules, Robert J. Peroni
University of Miami Law Review
No abstract provided.
Selected International Aspects Of Fundamental Tax Reform Proposals, Stephen E. Shay, Victoria P. Summers
Selected International Aspects Of Fundamental Tax Reform Proposals, Stephen E. Shay, Victoria P. Summers
University of Miami Law Review
No abstract provided.
Comment On Shay And Summers: Selected International Aspects Of Fundamental Tax Reform Proposals, Reuven S. Avi-Yonah
Comment On Shay And Summers: Selected International Aspects Of Fundamental Tax Reform Proposals, Reuven S. Avi-Yonah
University of Miami Law Review
No abstract provided.
The Hidden Costs Of The Progressivity Debate, Nancy C. Staudt
The Hidden Costs Of The Progressivity Debate, Nancy C. Staudt
Vanderbilt Law Review
Progressive taxation-taxing high income individuals at a proportionally higher level than low income individuals-has sparked more than a century of controversy. Those who support progressive taxation have heralded it as a policy that promotes the greatest good for the greatest number in society protects traditional democratic values, reflects the communitarian world-view of women who see themselves as responsible for the well-being of all individuals, and reveals the "aesthetic judgment" that income inequality is "distinctly evil or unlovely." At the same time, critics have condemned progressive income taxation as social policy that amounts to theft and involuntary servitude, reflects the democratic …
Government Precommitment To Tax Incentive Subsidies: The Impact Of United States V. Winstar Corp. On Retroactive Tax Legislation, Daniel S. Goldberg
Government Precommitment To Tax Incentive Subsidies: The Impact Of United States V. Winstar Corp. On Retroactive Tax Legislation, Daniel S. Goldberg
Faculty Scholarship
No abstract provided.
Taxation Of Telecommunications And Electronic Commerce, Walter Hellerstein
Taxation Of Telecommunications And Electronic Commerce, Walter Hellerstein
Scholarly Works
No abstract provided.
Hocking The Halo: Implications Of The Charities' Winning Briefs In Camps Newfound/Owatonna, Inc. (Symposium), Evelyn Brody
Hocking The Halo: Implications Of The Charities' Winning Briefs In Camps Newfound/Owatonna, Inc. (Symposium), Evelyn Brody
Evelyn Brody
No abstract provided.
The Deductibility Of Educational Costs: Why Does Congress Allow The Irs To Take Your Education So Personally?, I Jay Katz
Irwin J Katz
The most comprehensive historical article ever written regarding the IRS negative treatment regarding the deductibility of educational expenses as a legitimate section 162 deduction.
The Summons Power And The Limits Of Theory: A Reply To Professor Hyman, Leo P. Martinez
The Summons Power And The Limits Of Theory: A Reply To Professor Hyman, Leo P. Martinez
Faculty Scholarship
No abstract provided.
What's In A Name: An Argument For A Small Business Limited Liability Entity Statute (With Three Subsets Of Default Rules), Dale A. Oesterle, Wayne M. Gazur
What's In A Name: An Argument For A Small Business Limited Liability Entity Statute (With Three Subsets Of Default Rules), Dale A. Oesterle, Wayne M. Gazur
Publications
The recent proliferation of small business entity forms is primarily a result of their tax characterization. With the recent adoption of the IRS "check-the-box" regulations and, as a consequence, the elimination of traditional tax distinctions, many of these forms have lost their appeal. This article proposes starting over with one form, the "limited liability entity." Part I discusses the history of small business forms. Part II analyzes the current forms in light of the recent check-the- box legislation. Part III discusses the necessity of and rationale behind a unified entity statute. Finally, Part IV outlines a unified limited liability entity …
A New Direction For State Corporate Codes, Mark J. Loewenstein
A New Direction For State Corporate Codes, Mark J. Loewenstein
Publications
No abstract provided.
Tax And The Married Woman, Lawrence A. Zelenak
Tax And The Married Woman, Lawrence A. Zelenak
Faculty Scholarship
Reviewing, Edward J. McCaffery, Taxing Women (1997)