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Taxation-Federal

Selected Works

2010

Articles 1 - 11 of 11

Full-Text Articles in Law

Panelist, Oecd Conference On Intangibles, Hugh Ault Nov 2010

Panelist, Oecd Conference On Intangibles, Hugh Ault

Hugh J. Ault

No abstract provided.

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What Tax Lawyers Need To Know Before Choosing A Forum For Their Next Federal Civil Tax Litigation Dispute, Robert D. Probasco Oct 2010

What Tax Lawyers Need To Know Before Choosing A Forum For Their Next Federal Civil Tax Litigation Dispute, Robert D. Probasco

Robert Probasco

No abstract provided.

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Quoted In Bna Daily Tax Report On Uncertain Tax Positions Guidance, Robert D. Probasco Oct 2010

Quoted In Bna Daily Tax Report On Uncertain Tax Positions Guidance, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposed Amendments To Treasury Circular 230, Robert D. Probasco, David Colmenero, Mandi L. Matlock Oct 2010

Comments On Proposed Amendments To Treasury Circular 230, Robert D. Probasco, David Colmenero, Mandi L. Matlock

Robert Probasco

The vast majority of federal individual income tax return s are prepared by paid tax return preparers or by taxpayers using consumer tax preparation software. Circular 230 governs practice before the Service by attorneys, certified public accountants, enrolled agents, enrolled actuaries, and enrolled retirement plan agents (collectively, "practitioners" ). Circular 230, however, has not applied to paid tax return preparers who did not fall within any of the categories of practitioners. Various observers, including the National Taxpayer Advocate and consumer advocacy groups, have expressed significant concerns about the lack of regulation of such unenrolled tax return preparers. 1n June 2009, …

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Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault Jul 2010

Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault

Hugh J. Ault

No abstract provided.

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Transfer Pricing, Hugh Ault Jul 2010

Transfer Pricing, Hugh Ault

Hugh J. Ault

Chaired meeting of 45 governmental and academic specialist

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Federal Tax Update, Robert D. Probasco Jun 2010

Federal Tax Update, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposal Regarding Uncertain Tax Positions, Robert D. Probasco, Bruce Bernstien, Mark Horowitz May 2010

Comments On Proposal Regarding Uncertain Tax Positions, Robert D. Probasco, Bruce Bernstien, Mark Horowitz

Robert Probasco

These comments are presented on behalf of the Section of Taxation of the State Bar of Texas. The principal drafters of these comments were Robert D. Probasco, Mark Horowitz and Bruce Bemstien. Additional contributors were Val J. Albright, David E. Colmenero, Joel N. Crouch, Brian Dethrow, Kenneth M. Horwitz and Ronald D. Kerridge. The Committee on Government Submissions (COGS) of the Section of Taxation of the State Bar of Texas has approved these comments. Daniel G. Baucum is the Chair of COGS, and Emily Parker and Daniel J. Micciche reviewed the comments on behalf of COGS.

The following comments are …

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In Whom We Trust, Temple K. Fogg Jan 2010

In Whom We Trust, Temple K. Fogg

T. Keith Fogg

The Internal Revenue Service ("IRS") collects the majority of taxes through business entities that are required to withhold taxes from wages or collect excise taxes at the time of providing services. These business entities hold the taxes they collect in trust for the IRS. The wast majority of business entities pay over the taxes held in trust in a timely and appropriate manner; however, a sizeable amount, in dollar terms, does not get paid. Aside from passing criminal laws at or near the passage of the 1954 code, Congress has done little to create a structure that provides incentives for …

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Comparative Income Taxation: A Structural Analysis, Hugh Ault, Brian Arnold Dec 2009

Comparative Income Taxation: A Structural Analysis, Hugh Ault, Brian Arnold

Hugh J. Ault

The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime …

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Avoiding Misuse Of Donor Advised Funds, Michael Hussey Dec 2009

Avoiding Misuse Of Donor Advised Funds, Michael Hussey

Michael Hussey

No abstract provided.

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