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Full-Text Articles in Law

How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber Jan 2017

How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber

Journal of Law and Policy

The ratification of the Sixteenth Amendment to the United States Constitution granted Congress the right to tax income “from whatever source derived.” Since its inception, the tax code has become long and complicated, filled with broad taxation rules and innumerable exceptions. Over time, the tax code has been amended with the stated purpose of promoting “fairness, efficiency, and enforceability.” However, the complexity of the tax code has led to abuse of “tax loopholes” by wealthy taxpayers who want to avoid paying their fair share of taxes. While abuse is likely to continue, as legislators remain intent on lowering taxes on …


How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber Jan 2017

How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber

Journal of Law and Policy

The ratification of the Sixteenth Amendment to the United States Constitution granted Congress the right to tax income “from whatever source derived.” Since its inception, the tax code has become long and complicated, filled with broad taxation rules and innumerable exceptions. Over time, the tax code has been amended with the stated purpose of promoting “fairness, efficiency, and enforceability.” However, the complexity of the tax code has led to abuse of “tax loopholes” by wealthy taxpayers who want to avoid paying their fair share of taxes. While abuse is likely to continue, as legislators remain intent on lowering taxes on …


Federal Tax Update: Structuring Deals In 2012 And Beyond (Slides), Stephen L. Owen Nov 2012

Federal Tax Update: Structuring Deals In 2012 And Beyond (Slides), Stephen L. Owen

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2010

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

This recent developments outline discusses, and provides context to understand the significance of, the most important judicial decisions and administrative rulings and regulations promulgated by the Internal Revenue Service and Treasury Department during the most recent twelve months - and sometimes a little farther back in time if we find the item particularly humorous or outrageous. Most Treasury Regulations, however, are so complex that they cannot be discussed in detail and, anyway, only a devout masochist would read them all the way through; just the basic topic and Jundamental principles are highlighted - unless one of us decides to go …


Capturing Capital Gain While Staying In The Deal, Thomas P. Rohman, Todd D. Golub Nov 2008

Capturing Capital Gain While Staying In The Deal, Thomas P. Rohman, Todd D. Golub

William & Mary Annual Tax Conference

No abstract provided.


Tax Planning, Imbalance And Production, Yoseph M. Edrey Prof., Yoram Y. Margaliot, Eyal Sulganik, Rafael Eldor Jan 2004

Tax Planning, Imbalance And Production, Yoseph M. Edrey Prof., Yoram Y. Margaliot, Eyal Sulganik, Rafael Eldor

Yoseph M. Edrey

The paper analyzes the case of tax planning that tilts the government gain/loss ratio below one, and provides a proof of a certain type of inefficiency caused by tax planning. As the paper shows, the tax imbalance distorts the firm's output level, providing the firm with an incentive to produce more than the social optimum. This inefficiency is different from the general inefficiency entailed by income taxation, captured by the conventional notion of excess burden. The paper also examines the determinants of this type of distortion and offers some policy implications.


Capital Gains And Losses - As Affected By The Tax Reform Act Of 1969, Arnold C. Johnson Dec 1970

Capital Gains And Losses - As Affected By The Tax Reform Act Of 1969, Arnold C. Johnson

William & Mary Annual Tax Conference

No abstract provided.


Federal Income Tax-Liquidation-Re-Incorporation: The Current Approach And A Proposed Alternative, A. Ennis Dale Jul 1968

Federal Income Tax-Liquidation-Re-Incorporation: The Current Approach And A Proposed Alternative, A. Ennis Dale

Indiana Law Journal

No abstract provided.


Federal Taxation - Depreciation Of Assets In The Year Of Disposal Jan 1964

Federal Taxation - Depreciation Of Assets In The Year Of Disposal

William & Mary Law Review

No abstract provided.