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Articles 1 - 30 of 32
Full-Text Articles in Law
Basing Budget Baselines, David Kamin
Basing Budget Baselines, David Kamin
William & Mary Law Review
Measuring the cost of legislation or even projecting the course of the federal budget requires defining a budget baseline—a starting point capturing the current state of the budget. Budget baselines underlie most measures employed in federal budget debates and enforcement rules. Yet, despite their widespread use, budget baselines engender considerable confusion and abuse.
For instance, when legislators enact temporary tax breaks, the breaks are officially estimated to cost far less than they likely will because of a loophole in federal budget baseline rules. Then, later efforts to extend the tax cuts are counted as increasing deficits when, in fact, by …
The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll
The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll
William & Mary Law Review
In this Article, I estimate the tax revenue effects of taxing private equity carried interests as ordinary income rather than as long-term capital gain as under current law. Under reasonable assumptions, I conclude that the expected present value of additional tax collections would be between 1 percent and 1.5 percent of capital invested in private equity funds, or between $2 billion and $3 billion a year. That estimate, however, makes no allowance for changes in the structure of such funds or the composition of the partnerships, which might substantially reduce tax revenues below those estimates.
Entity Theory As Myth In The Origins Of The Corporate Income Tax, Steven A. Bank
Entity Theory As Myth In The Origins Of The Corporate Income Tax, Steven A. Bank
William & Mary Law Review
No abstract provided.
A Historical Essay And Economic Assay Of The Capital Asset Definition: The Taxpayer And Courts Are Still Mindfully Guessing While Congress Doesn't Seem To (Have A) Mind, Joseph Byron Cartee
A Historical Essay And Economic Assay Of The Capital Asset Definition: The Taxpayer And Courts Are Still Mindfully Guessing While Congress Doesn't Seem To (Have A) Mind, Joseph Byron Cartee
William & Mary Law Review
No abstract provided.
Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer
Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer
William & Mary Law Review
No abstract provided.
Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status
Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status
William & Mary Law Review
No abstract provided.
The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott
The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott
William & Mary Law Review
No abstract provided.
Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson
Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson
William & Mary Law Review
No abstract provided.
Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr.
Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr.
William & Mary Law Review
No abstract provided.
Tax Planning For The Not-So-Rich: Variable And Private Annuities, Anthony M. Vernava
Tax Planning For The Not-So-Rich: Variable And Private Annuities, Anthony M. Vernava
William & Mary Law Review
No abstract provided.
Federal Taxation - Accumulated Earnings Tax - The Quantum Of Tax Avoidance Purpose Required - United States V. Donruss, 89 S. Ct. 501 (1969), Robert S. Parker Jr.
Federal Taxation - Accumulated Earnings Tax - The Quantum Of Tax Avoidance Purpose Required - United States V. Donruss, 89 S. Ct. 501 (1969), Robert S. Parker Jr.
William & Mary Law Review
No abstract provided.
Federal Taxation - Professional Service Corporation - Corporate Versus Partnership Statute - Empey V. United States, __ F. 2d __ (10th Cir. 1969)., Haldane Robert Mayer
Federal Taxation - Professional Service Corporation - Corporate Versus Partnership Statute - Empey V. United States, __ F. 2d __ (10th Cir. 1969)., Haldane Robert Mayer
William & Mary Law Review
No abstract provided.
Non-Business Guaranty Loss: Ordinary Or Capital Deduction, Robert S. Parker Jr.
Non-Business Guaranty Loss: Ordinary Or Capital Deduction, Robert S. Parker Jr.
William & Mary Law Review
No abstract provided.
Book Review Of Items Of Gross Income, Emeric Fischer
Book Review Of Items Of Gross Income, Emeric Fischer
William & Mary Law Review
No abstract provided.
The Treatment Of Income & Deductions In The Case Of Controlled Or Related Entities, William H. Westphal
The Treatment Of Income & Deductions In The Case Of Controlled Or Related Entities, William H. Westphal
William & Mary Law Review
No abstract provided.
The Reincorporation Problem In Subchapter C. A Question Of Semantics?, R. P. Hertzog
The Reincorporation Problem In Subchapter C. A Question Of Semantics?, R. P. Hertzog
William & Mary Law Review
No abstract provided.
Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen
Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen
William & Mary Law Review
No abstract provided.
Simplification And Equity As Goals Of Tax Policy, Stanley S. Surrey, Gerard M. Brannon
Simplification And Equity As Goals Of Tax Policy, Stanley S. Surrey, Gerard M. Brannon
William & Mary Law Review
No abstract provided.
Tax Legislation Of 1966, John E. Donaldson
Tax Legislation Of 1966, John E. Donaldson
William & Mary Law Review
No abstract provided.
Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer
Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer
William & Mary Law Review
No abstract provided.
Federal Taxation - Depreciation Of Assets In The Year Of Disposal
Federal Taxation - Depreciation Of Assets In The Year Of Disposal
William & Mary Law Review
No abstract provided.
The New "Subpart F" Foreign Income Provisions Of The Internal Revenue Code, Rexford R. Cherryman
The New "Subpart F" Foreign Income Provisions Of The Internal Revenue Code, Rexford R. Cherryman
William & Mary Law Review
No abstract provided.
The Reconstruction Of Net Income Under § 446(B) Of The Internal Revenue Code, John J. Harrington
The Reconstruction Of Net Income Under § 446(B) Of The Internal Revenue Code, John J. Harrington
William & Mary Law Review
No abstract provided.
Tax Planning For The Hobby Enthusiast, Daniel U. Livermore Jr.
Tax Planning For The Hobby Enthusiast, Daniel U. Livermore Jr.
William & Mary Law Review
No abstract provided.
Federal Income Taxation: Meals And Lodging Furnished For The Convenience Of The Employer - Two Sequels To The Boykin Case, Rexford R. Cherryman
Federal Income Taxation: Meals And Lodging Furnished For The Convenience Of The Employer - Two Sequels To The Boykin Case, Rexford R. Cherryman
William & Mary Law Review
No abstract provided.
The Deductability Of Moving Expenses And Investigatory Expenses, Bernard Goldstein
The Deductability Of Moving Expenses And Investigatory Expenses, Bernard Goldstein
William & Mary Law Review
No abstract provided.
The Civil Aspects Of The Net Worth Method, Richard D. Schwab
The Civil Aspects Of The Net Worth Method, Richard D. Schwab
William & Mary Law Review
No abstract provided.
Federal Income Taxation: Deductability Of Medical Expenses Which Are Also Personal Expenses, Ronald L. Buckwalter
Federal Income Taxation: Deductability Of Medical Expenses Which Are Also Personal Expenses, Ronald L. Buckwalter
William & Mary Law Review
No abstract provided.
Taxation, Amount Received For Future Damages, John J. Harrington
Taxation, Amount Received For Future Damages, John J. Harrington
William & Mary Law Review
No abstract provided.
Tax Effects Of Divorce, Marital Separation And Support Agreement, Lester I. Bowman
Tax Effects Of Divorce, Marital Separation And Support Agreement, Lester I. Bowman
William & Mary Law Review
No abstract provided.