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Full-Text Articles in Law
Rsp Redux: Is Irc Section 83’S Overreach “In [C]Onnection With The [P]Erformance Of [S]Ervices” The Real “[U]Nwarranted And [U]Nintended” Result?, Charles F. Mccormick
Rsp Redux: Is Irc Section 83’S Overreach “In [C]Onnection With The [P]Erformance Of [S]Ervices” The Real “[U]Nwarranted And [U]Nintended” Result?, Charles F. Mccormick
The Business, Entrepreneurship & Tax Law Review
This article analyzes the effects of IRC § 83 from the perspective of those most often subject to it. While § 83 remains a critical tax consideration for entrepreneurs, this article concludes that § 83 has become, in practice, a solution searching for a problem that in fact causes more problems than it solves. Drafters of § 83 believed they were closing a significant loophole regarding the taxation of executive compensation. Looking at the problem legislators believed they were solving in the context of contemporary executive compensation structures, it is hard to understand what the actual problem was. Section 83(b) …
A Comparison Between The U.S. And Japan Concerning The Tax Treatment Of Prepaid Income, Hiroshi Noguchi
A Comparison Between The U.S. And Japan Concerning The Tax Treatment Of Prepaid Income, Hiroshi Noguchi
The Business, Entrepreneurship & Tax Law Review
This article examines the crucial distinctions of methodology between the U.S. and the Japanese tax laws with respect to the timing for recognizing income. In addition, it studies the advantages and disadvantages of both tax treatment methods concerning prepaid income. As a result, it concludes that the advantages of Japanese tax law concerning prepaid income outweigh those of the American tax law. This article also suggests that U.S. tax law could borrow the Japanese mentality regarding the tax treatment of prepaid income.