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Articles 1 - 22 of 22
Full-Text Articles in Law
Deferral: Consider Ending It Instead Of Expanding It, J. Clifton Fleming Jr.
Deferral: Consider Ending It Instead Of Expanding It, J. Clifton Fleming Jr.
Faculty Scholarship
No abstract provided.
Investing For After-Tax Returns: An Overview, Anne B. Shumadine
Investing For After-Tax Returns: An Overview, Anne B. Shumadine
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments In Federal Income Taxation, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation, Ira B. Shepard, Martin J. Mcmahon Jr.
William & Mary Annual Tax Conference
No abstract provided.
Preslar V. Commissioner: Debt-Discharge Income And Its Rationale, Chad J. Pomeroy
Preslar V. Commissioner: Debt-Discharge Income And Its Rationale, Chad J. Pomeroy
BYU Law Review
No abstract provided.
The Death Of The Income Tax (Or, The Rise Of America’S Universal Wage Tax), Edward J. Mccaffery
The Death Of The Income Tax (Or, The Rise Of America’S Universal Wage Tax), Edward J. Mccaffery
Indiana Law Journal
The killing of the income tax has not been open and notorious: such is not the style of contemporary politics. As with other markers of progressive social policy—the promises of universal health care, Obamacare, come to mind6—the income tax is dying a death by stealth, albeit stealth played out in plain view. The plot lines of the tragedy are apparent. The individual “income” tax has been split in two. One tax, for the masses, is a simple, increasingly formless wage tax. This wage/income tax adds higher brackets onto the payroll tax, the model toward which the wage/income tax aims, to …
After Drye: The Likely Attachment Of The Federal Tax Lien To Tenancy-By-The-Entireties, Steve R. Johnson
After Drye: The Likely Attachment Of The Federal Tax Lien To Tenancy-By-The-Entireties, Steve R. Johnson
Scholarly Publications
On December 7, 1999, the United States Supreme Court unanimously decided Drye v. United States, a case likely to be a landmark in federal tax lien law. Drye clarified what had been muddied by previous Supreme Court and lower court decisions: the proper relation between state law and federal law in tax lien attachment cases. That clarification will permit-indeed, compel-greater analytical precision as future courts address tax lien cases. This Article discusses one such line of cases.
It has long been the rule that the federal tax lien does not attach to tenancy-by-the entireties interests when (1) only one of …
Bad Drafting - A Case Study Of The Design And Implementation Of The Income Tax Subsidies For Education, Glenn E. Coven
Bad Drafting - A Case Study Of The Design And Implementation Of The Income Tax Subsidies For Education, Glenn E. Coven
Faculty Publications
No abstract provided.
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Hugh J. Ault
No abstract provided.
A Residual Damages Right Against The Irs: A Cure Worse Than The Disease, Steve R. Johnson
A Residual Damages Right Against The Irs: A Cure Worse Than The Disease, Steve R. Johnson
Scholarly Publications
Tax scholarship commonly has emphasized the substantive rules of tax liability, according less than due attention to tax procedure. Recently, however, this imbalance has been partly redressed as a result of the taxpayer rights movement. The major legislative products of the movement have been the Taxpayer Bill of Rights (TBORl) in 1988, the Taxpayer Bill of Rights 2 (TBOR2) in 1996,and the Taxpayer Bill of Rights (TBOR3) in 1998. Congress currently is considering a fourth installment in the series. These measures – especially TBOR3 – have provoked considerable useful commentary from both practitioners and academics.
Nonetheless, much work remains to …
Federal Taxation, Kimberly S. Piar, Donald P. Hensel, M. Todd Prewett, Donald R. Bly
Federal Taxation, Kimberly S. Piar, Donald P. Hensel, M. Todd Prewett, Donald R. Bly
Mercer Law Review
In 1999 the Eleventh Circuit Court of Appeals decided several substantive tax cases as well as a number of procedural cases. The substantive tax issues addressed by the court included the definition of "control" under Internal Revenue Code Section 1504(a); whether S corporation shareholders can increase basis in their stock by the amount of guaranteed loans; the allocation of the purchase price of real property among depreciable and nondepreciable assets; employment tax issues; and worthless debt deductions under Internal Revenue Code Section 166. As to procedural issues, the court decided cases relating to remittances made in connection with Form 4868, …
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
Evelyn Brody
This piece, included in the University of Hawaii Law Review's symposium issue on the Bishop Estate, explores the relationship between the new intermediate sanctions law and the IRS's power to revoke tax exemption under § 501(c)(3). Inspired by the storied setting, I indulge in a fantasy: This article pretends that the IRS revoked the Estate's exemption, and takes the form of the Tax Court declaratory judgment opinion. I reluctantly 'rule' that exemption was not appropriate, because State enforcement action against the trustees was proceeding. (However, this forum allows me to hedge my argument by producing two concurring and one dissenting …
It's A Wonderful Life Insurance Policy: Determining The Correct Theory To Tax The Employee In Employer-Pay-All Equity Split-Dollar Life Insurance Arrangements, I Jay Katz
Irwin J Katz
A look at the taxation of split-dollar life insurance at the height of its popularity.
Unfinished Business On The Taxpayer Rights Agenda: Achieving Fairness In Transferee Liability Cases, Steve R. Johnson
Unfinished Business On The Taxpayer Rights Agenda: Achieving Fairness In Transferee Liability Cases, Steve R. Johnson
Scholarly Publications
The taxpayer rights movement has been a driving force of tax legislation and administration for over a decade. It has produced the Taxpayer Bill of Rights (TBOR) in 1988, the Taxpayer Bill of Rights 2 (TBOR2) in 1996, the Taxpayer Bill of Rights 3 (TBOR3) in 1998, lesser statutory initiatives, and an array of important administrative changes by the Service. While the future of the movement can be debated, it is clear that, for now, it remains a force to be reckoned with in tax policy.
This article advances a proposal to extend and complete one thrust of the taxpayer …
A Discussion Of The Application Of Fica And Futa To Indian Tribes' On-Reservation Activities, Robyn L. Robinson
A Discussion Of The Application Of Fica And Futa To Indian Tribes' On-Reservation Activities, Robyn L. Robinson
American Indian Law Review
No abstract provided.
Unfinished Business On The Taxpayer Rights Agenda: Achieving Fairness In Transferee Liability Cases, Steve R. Johnson
Unfinished Business On The Taxpayer Rights Agenda: Achieving Fairness In Transferee Liability Cases, Steve R. Johnson
Articles by Maurer Faculty
No abstract provided.
Corporate Finance, Corporate Law And Finance Theory, Peter H. Huang, Michael S. Knoll
Corporate Finance, Corporate Law And Finance Theory, Peter H. Huang, Michael S. Knoll
All Faculty Scholarship
No abstract provided.
A Comprehensive Wealth Tax, David Shakow, Reed Shuldiner
A Comprehensive Wealth Tax, David Shakow, Reed Shuldiner
All Faculty Scholarship
Income, consumption, and wealth are all possible bases for a tax system in the United States. Scholars have specified the structure of income tax and consumption taxes, but no one has attempted to describe in detail a comprehensive wealth tax for the United States. In this paper, we begin to develop such a structure. In particular, we hypothesize that the combination of a flat rate tax on networth and a flat rate tax on earned income along with an appropriate level of exemptions, could be an attractive tax base. In order to explore the structure of a wealth tax, we …
News Flash: The Income Tax Remains Constitutional, Erik M. Jensen
News Flash: The Income Tax Remains Constitutional, Erik M. Jensen
Faculty Publications
No abstract provided.
The Tax Of Physics, The Physics Of Tax, Stephen B. Cohen
The Tax Of Physics, The Physics Of Tax, Stephen B. Cohen
Georgetown Law Faculty Publications and Other Works
Sometimes ideas from science illuminate muddled legal thinking. Physics teaches that, for every particle of matter, there exists a corresponding particle of anti-matter. A particle of matter and its corresponding particle of anti-matter are identical except that they have opposite electrical charges. A proton's charge is positive, an anti-proton's negative. When matter and anti-matter meet, they produce the most powerful explosion in nature, totally annihilating each other.
With these laws of physics in mind, consider that a donor can make a gift in one of two ways: either by assuming a debt or by transferring as asset. In an instance …
Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch
Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch
LLM Theses and Essays
The instant thesis is organized in three main parts. The first contains an overview of U.S. law including constitutional issues of the topic focusing on the separation of tax powers between federal and state authorities with special attention to the basis and extent to which a State is entitled to impose levies on business organizations; a brief analysis of federal legislation allowing the pass-through regime; and summary concerning LLC legislation in the States. The second analyzes the application of the main, basic principles of international taxation (such as residence, source rules, application of international treaties, and connected with it the …
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Hugh J. Ault
No abstract provided.
Internet: Taxar Ou Não Taxar?, Ivo T. Gico
Internet: Taxar Ou Não Taxar?, Ivo T. Gico
Ivo Teixeira Gico Jr.
O artigo demonstra a opinião do autor acerca de manifestações sobre tributação da internet, sustentando o potencial nocivo à democratização da informação. The article demonstrates the author's opinion about taxing the Internet and its potential harm to the democratization of information.