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Articles 1 - 21 of 21
Full-Text Articles in Law
Codification Of The Economic Substance Doctrine: Agency Response And Certain Other Unforeseen Consequences, Rebecca Rosenberg
Codification Of The Economic Substance Doctrine: Agency Response And Certain Other Unforeseen Consequences, Rebecca Rosenberg
William & Mary Business Law Review
Section 7701(o) of the Internal Revenue Code incorporates the controversial judicial doctrine of economic substance into statutory language. In other words, it “codifies” the doctrine. (The economic substance doctrine generally provides that a tax benefit that goes beyond Congressional intent can be disallowed by the courts, even if the taxpayer meets all of the literal Code and regulatory requirements for claiming the benefit.)
This codification appears to have accidentally dissuaded the relevant agency (the Internal evenue Service, or IRS) from raising economic substance issues—an effect that is contrary to Congress’s intent in enacting the doctrine into legislation. Essentially, Congress imported …
Politics Of Tax Reform: Outline, Evan M. Migdail
Politics Of Tax Reform: Outline, Evan M. Migdail
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entity After Tax Reform – The New Normal (Outline), N. Pendleton Rogers
Choice Of Entity After Tax Reform – The New Normal (Outline), N. Pendleton Rogers
William & Mary Annual Tax Conference
No abstract provided.
New Rules Of The Road For Interest And Depreciation Deductions And Like-Kind Exchanges After Tax Reform (Powerpoint), Robert D. Schachat
New Rules Of The Road For Interest And Depreciation Deductions And Like-Kind Exchanges After Tax Reform (Powerpoint), Robert D. Schachat
William & Mary Annual Tax Conference
No abstract provided.
Powers Of Deduction: Tax-Saving Strategies Under The Legislation Formerly Known As The Tax Cuts And Jobs Act (Powerpoint), Thomas J. Pauloski
Powers Of Deduction: Tax-Saving Strategies Under The Legislation Formerly Known As The Tax Cuts And Jobs Act (Powerpoint), Thomas J. Pauloski
William & Mary Annual Tax Conference
No abstract provided.
Federal Tax Update (Powerpoint), Stephen L. Owen
Federal Tax Update (Powerpoint), Stephen L. Owen
William & Mary Annual Tax Conference
No abstract provided.
When Are You An Investor Versus A Dealer In Real Property? (Powerpoint), James B. Sowell, Stephen J. Giordano
When Are You An Investor Versus A Dealer In Real Property? (Powerpoint), James B. Sowell, Stephen J. Giordano
William & Mary Annual Tax Conference
No abstract provided.
Applying The New 20% Passthroughs Deduction Under Section 199a In The Real World (Powerpoint), James B. Sowell, Stephen J. Giordano, Mark C. Van Deusen
Applying The New 20% Passthroughs Deduction Under Section 199a In The Real World (Powerpoint), James B. Sowell, Stephen J. Giordano, Mark C. Van Deusen
William & Mary Annual Tax Conference
No abstract provided.
Mergers And Acquisitions Of Closely-Held Corporations (Powerpoint), Jerald D. August
Mergers And Acquisitions Of Closely-Held Corporations (Powerpoint), Jerald D. August
William & Mary Annual Tax Conference
No abstract provided.
Nonqualified Employee Benefits For Privately-Held Companies – Equity And Deferred Compensation Opportunities (Outline), Taylor W. French, G. William Tysse
Nonqualified Employee Benefits For Privately-Held Companies – Equity And Deferred Compensation Opportunities (Outline), Taylor W. French, G. William Tysse
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments In Virginia Taxation, Craig D. Bell
Recent Developments In Virginia Taxation, Craig D. Bell
William & Mary Annual Tax Conference
No abstract provided.
International Provisions Of Public Law No. 115-97 (The “Tcja”) (Powerpoint), William B. Sherman
International Provisions Of Public Law No. 115-97 (The “Tcja”) (Powerpoint), William B. Sherman
William & Mary Annual Tax Conference
No abstract provided.
At A Loss: Excess Business Loss And Nol Provisions Of The Tcja (Powerpoint), Brian J. O'Connor, Stephen M. Sharkey
At A Loss: Excess Business Loss And Nol Provisions Of The Tcja (Powerpoint), Brian J. O'Connor, Stephen M. Sharkey
William & Mary Annual Tax Conference
No abstract provided.
Advising Partners And Partnerships Under The New Centralized Partnership Audit Rules: The Need To Amend Partnership And Llc Operating Agreements (Powerpoint), Jerald D. August
Advising Partners And Partnerships Under The New Centralized Partnership Audit Rules: The Need To Amend Partnership And Llc Operating Agreements (Powerpoint), Jerald D. August
William & Mary Annual Tax Conference
No abstract provided.
Mergers And Acquisitions Of Closely-Held Corporations (Outline), Jerald D. August
Mergers And Acquisitions Of Closely-Held Corporations (Outline), Jerald D. August
William & Mary Annual Tax Conference
No abstract provided.
An Overview Of Partnerships (Powerpoint), Ari Berk, Drew Tidwell
An Overview Of Partnerships (Powerpoint), Ari Berk, Drew Tidwell
William & Mary Annual Tax Conference
No abstract provided.
2018 Tax Conference Speakers
William & Mary Annual Tax Conference
No abstract provided.
Directed Tax Holidays: Economic Stimulus Or Corporate Dream?, Dakota Newton
Directed Tax Holidays: Economic Stimulus Or Corporate Dream?, Dakota Newton
William & Mary Business Law Review
U.S. corporations currently have more than $2.4 trillion stashed in the accounts of their overseas subsidiaries—a sum that costs the domestic economy billions of dollars every year. A directed tax holiday is one potential method of inducing repatriation of those funds and stimulating the domestic economy. Although a previous tax holiday failed to meet expectations, current proposals from the public and private sectors suggest that a directed tax holiday could fund much-needed infrastructure investment. A review and economic analysis of these proposals shows that a directed tax holiday that channels revenue into expanding and updating infrastructure will greatly benefit the …
The Natural Property Rights Straitjacket: The Takings Clause, Taxation, And Excessive Rigidity, Eric Kades
The Natural Property Rights Straitjacket: The Takings Clause, Taxation, And Excessive Rigidity, Eric Kades
Faculty Publications
Natural property rights theories have become the primary lens through which conservative jurists and scholars view the Constitution’s main property rights provision, the Takings Clause. One of their most striking arguments is that progressive income taxation — applying higher tax rates to higher incomes — is an unconstitutional taking of wealthy taxpayers’ property. This has become part and parcel of well-established battle lines between conservative property rights advocates and their liberal counterparts. What has gone unnoticed is that the very same argument deployed against progressive taxation also deems regressive taxation — applying lower tax rates to higher incomes — an …