Law Commons^™

Economic Substance And The Supreme Court, Amandeep S. Grewal

Andy Grewal

The Supreme Court grants certiorari in a wide variety of fascinating cases. Occasionally, it agrees to decide tax cases, too. Perhaps because of the perceived dryness of tax law, the Court has been hesitant to address the validity of the so-called economic substance doctrine. Although there are too many formulations of the doctrine to count, the lower courts often hold that even when a taxpayer has met a statute's requirements, he cannot enjoy any of its benefits unless his conduct reveals a business purpose and a reasonable expectation of profit. This article argues that the lower courts' application of an …

Lecture, “Current Issues In Us-Swedish Tax Relationships, Hugh Ault

Hugh J. Ault

No abstract provided.

Lecture, “The Work Of The Oecd In International Tax Matters, Recent Developments, Hugh Ault

Hugh J. Ault

No abstract provided.

Ethics And Standards Of Tax Practice In The New Age Of Transparency: From Self-Assessment To Self-Audit, Emily A. Parker, Robert D. Probasco

Robert Probasco

No abstract provided.

Lecture, 21st Century Challenges For Tax Policy Makers And Tax Administrators, Hugh Ault

Hugh J. Ault

No abstract provided.

Comments On Proposed Regulations On Reportable Transactions, Robert D. Probasco, M. Todd Welty, Brandy N. Williams, Stephen A. Beck

Robert Probasco

Repairing Facade Easements: Is This The Gift That Launched A Thousand Deductions?, Martha Jordan

Martha W. Jordan

This article explores the impact of such a covenant on the characterization for tax purposes of expenditures to maintain the facade. In particular this article explores the following question: Given that the charitable easement holder owns a nonpossessory interest in the facade, which imposes on the charity an obligation to repair and maintain the facade and entitles it to benefit from increases in the value of the facade, is a donor's assumption of the charity's obligation to repair the facade an additional charitable contribution to the charity? If a donor gratuitously makes improvements to property owned outright by a charity, …

Using Insurance Law And Policy To Interpret The Tax Code's Loss And Medical Expense Provisions, Andrew Blair-Stanek

Andrew Blair-Stanek

No abstract provided.