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Articles 1 - 18 of 18
Full-Text Articles in Law
Ending The Irs As We Know It: Thoughts From Outside The Beltway, J. Clifton Fleming Jr.
Ending The Irs As We Know It: Thoughts From Outside The Beltway, J. Clifton Fleming Jr.
Faculty Scholarship
No abstract provided.
Recent Developments Affecting Worker Classification Disputes With The Internal Revenue Service, L. Paige Marvel
Recent Developments Affecting Worker Classification Disputes With The Internal Revenue Service, L. Paige Marvel
William & Mary Annual Tax Conference
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.
'Complete' Accrual Taxation, Fred B. Brown
'Complete' Accrual Taxation, Fred B. Brown
All Faculty Scholarship
Under the realization rule, accrued gains and losses generally are not taken into account for income tax purposes until a disposition occurs. Thus, the realization rule is responsible for tax deferral, which in turn likely leads to economic inefficiencies and inequities. The realization rule also contributes greatly to the complexity of the federal income tax system by necessitating numerous Internal Revenue Code provisions that address the many consequences arising from the decision to postpone taxation until a disposition occurs.
An alternative to the realization rule is accrual taxation - the inclusion in the tax base of annual increases and decreases …
Speculating On The Future Of Attorney Responsibility To Nonclients, Barbara Glesner Fines
Speculating On The Future Of Attorney Responsibility To Nonclients, Barbara Glesner Fines
Faculty Works
No abstract provided.
Toward A Tax-Based Explanation Of The Liability Insurance Crisis, Kyle D. Logue
Toward A Tax-Based Explanation Of The Liability Insurance Crisis, Kyle D. Logue
Articles
The so-called liability insurance crisis of 1985 and 1986 transformed the way we think about tort law and about liability insurance markets. The crisis phenomena, which first appeared in late 1984 and lasted until mid-1986, consisted of enormous increases in liability insurance premiums and alarming reductions in the availability of certain types of liability coverage. In the two principal liability lines of insurance (Other Liability and Medical Malpractice), premiums increased by hundreds (in some cases thousands) of percentage points in a matter of months. At the same time, the availability of liability insurance contracted sharply. The liability policies that were …
Irs Overhauls Spin-Off Ruling Guidelines, Stuart M. Finkelstein, Stuart G. Lazar
Irs Overhauls Spin-Off Ruling Guidelines, Stuart M. Finkelstein, Stuart G. Lazar
Other Scholarship
No abstract provided.
Of Fairness And Might: The Limits Of Sovereign Power To Tax After Winstar, Leo P. Martinez
Of Fairness And Might: The Limits Of Sovereign Power To Tax After Winstar, Leo P. Martinez
Faculty Scholarship
No abstract provided.
An Analysis Of The Disallowance Of Advertising Expenses For Tobacco Products, Ravi Mannam
An Analysis Of The Disallowance Of Advertising Expenses For Tobacco Products, Ravi Mannam
LLM Theses and Essays
Generally, reasonable expenses incurred in the ordinary and necessary course of a legitimate trade or business are deductible from gross income under the U.S. Tax Code; however in an effort to curb tobacco use, recent legislation has disallowed this benefit to tobacco companies for advertising expenses. The judiciary has upheld this disallowance under the doctrine of legislative grace. This thesis critiques the doctrine of legislative grace along with a review Congress’s power to tax income and the role of deductions. Also, the possibility of disallowing business expenses under public policy grounds is examined, and the relationship between lobbying expenses and …
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas
Cornell Law Faculty Publications
No abstract provided.
The American Dream In Legislation: The Role Of Popular Symbols In Wealth Tax Policy, William S. Blatt
The American Dream In Legislation: The Role Of Popular Symbols In Wealth Tax Policy, William S. Blatt
Articles
No abstract provided.
The Plethora Of Consumption Tax Proposals: Putting The Value Added Tax, Flat Tax, Retail Sales Tax, And Usa Tax Into Perspective, Alan Schenk
Law Faculty Research Publications
No abstract provided.
Reflections On Executive Compensation And A Modest Proposal For (Further) Reform, Mark J. Loewenstein
Reflections On Executive Compensation And A Modest Proposal For (Further) Reform, Mark J. Loewenstein
Publications
No abstract provided.
Tax Transitions, Opportunistic Retroactivity, And The Benefits Of Government Precommitment, Kyle D. Logue
Tax Transitions, Opportunistic Retroactivity, And The Benefits Of Government Precommitment, Kyle D. Logue
Articles
What if the current federal income tax laws were repealed and replaced with a simple flat tax? What if the entire Internal Revenue Code (with its graduated rates and countless deductions, exclusions, and credits) were scuttled in favor of a broad-based consumption tax? Only a few years ago, such proposals would have seemed radical and extremely unlikely to be adopted. But times are changing. Calls for a drastic overhaul of the Internal Revenue Code have become commonplace, even at the highest levels in the tax-policy community. In addition, proposals that would replace the income tax with a flat-rate broad-based consumption …
Tax Deduction Of Hazardous Waste Cleanup Costs: Harmonizing Federal Tax And Environmental Policies, Jeffrey M. Gaba
Tax Deduction Of Hazardous Waste Cleanup Costs: Harmonizing Federal Tax And Environmental Policies, Jeffrey M. Gaba
Faculty Journal Articles and Book Chapters
The issue of the deductibility of environmental cleanup costs involves the complex and painful intersection of tax and environmental law. The basic issue is whether environmental remediation costs may be immediately deducted as ordinary and necessary expenses or whether they must they be capitalized as improvements to land. A recent revenue ruling by the IRS, Rev. Rul. 94-38, addresses a relatively simple situation but basically leaves the most difficult issues unresolved.
This article discusses whether cleanup expenses may be immediately deducted when the payments were made by the current landowner and 1) the contamination was caused and cleaned up by …
The Excludability Of Employment Discrimination Awards Under Code Section 104(A)(2) After Burke V. United States And Commissioner V. Schleier, Leandra Lederman
The Excludability Of Employment Discrimination Awards Under Code Section 104(A)(2) After Burke V. United States And Commissioner V. Schleier, Leandra Lederman
Articles by Maurer Faculty
No abstract provided.
"Civil"Lzing Tax Procedure: Applying General Federal Learning To Statutory Notices Of Deficiency, Leandra Lederman
"Civil"Lzing Tax Procedure: Applying General Federal Learning To Statutory Notices Of Deficiency, Leandra Lederman
Articles by Maurer Faculty
Tax procedure has been rather isolated from the main currents of civil procedure. Using the statutory notice of deficiency as an exemplar, the article explores how viewing tax procedure issues from the perspective of general civil litigation can facilitate procedural regularity and foster fairness to United States Tax Court contestants. The statutory notice is the document by which the IRS forewarns a taxpayer of impending assessment of tax greater than the amount reported on the taxpayer's return. The article identifies three functions of the notice and their general civil litigation analogues. First, like legal process, it provides the taxpayer with …
Theories Of The Corporation And The Tax Treatment Of Corporate Philanthropy Symposium: Corporate Philanthropy Law, Culture, Education, And Politics, Linda Sugin
Faculty Scholarship
This essay is organized as follows: Part I describes the entity model of the corporation as developed in corporate and ethical theory, showing how that model is embodied in the Code and how variations in that model produce different conclusions about the legitimacy of the charitable contribution deduction for corporations. It discusses some issues that arise when corporate philanthropy is considered in the context of the entity theory and how the tax law might respond to those issues. Part II explains how the nexus-of-contracts conception of the corporation, applied as an analytical tool, challenges the tax law's treatment of corporate …