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Full-Text Articles in Law

Basing Budget Baselines, David Kamin Oct 2015

Basing Budget Baselines, David Kamin

William & Mary Law Review

Measuring the cost of legislation or even projecting the course of the federal budget requires defining a budget baseline—a starting point capturing the current state of the budget. Budget baselines underlie most measures employed in federal budget debates and enforcement rules. Yet, despite their widespread use, budget baselines engender considerable confusion and abuse.

For instance, when legislators enact temporary tax breaks, the breaks are officially estimated to cost far less than they likely will because of a loophole in federal budget baseline rules. Then, later efforts to extend the tax cuts are counted as increasing deficits when, in fact ...


The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll Oct 2008

The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll

William & Mary Law Review

In this Article, I estimate the tax revenue effects of taxing private equity carried interests as ordinary income rather than as long-term capital gain as under current law. Under reasonable assumptions, I conclude that the expected present value of additional tax collections would be between 1 percent and 1.5 percent of capital invested in private equity funds, or between $2 billion and $3 billion a year. That estimate, however, makes no allowance for changes in the structure of such funds or the composition of the partnerships, which might substantially reduce tax revenues below those estimates.


Entity Theory As Myth In The Origins Of The Corporate Income Tax, Steven A. Bank Dec 2001

Entity Theory As Myth In The Origins Of The Corporate Income Tax, Steven A. Bank

William & Mary Law Review

No abstract provided.


A Historical Essay And Economic Assay Of The Capital Asset Definition: The Taxpayer And Courts Are Still Mindfully Guessing While Congress Doesn't Seem To (Have A) Mind, Joseph Byron Cartee Mar 1993

A Historical Essay And Economic Assay Of The Capital Asset Definition: The Taxpayer And Courts Are Still Mindfully Guessing While Congress Doesn't Seem To (Have A) Mind, Joseph Byron Cartee

William & Mary Law Review

No abstract provided.


Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer Feb 1989

Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer

William & Mary Law Review

No abstract provided.


Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status May 1973

Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status

William & Mary Law Review

No abstract provided.


The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott Oct 1970

The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott

William & Mary Law Review

No abstract provided.


Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson May 1970

Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson

William & Mary Law Review

No abstract provided.


Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr. Mar 1970

Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr.

William & Mary Law Review

No abstract provided.


Tax Planning For The Not-So-Rich: Variable And Private Annuities, Anthony M. Vernava Oct 1969

Tax Planning For The Not-So-Rich: Variable And Private Annuities, Anthony M. Vernava

William & Mary Law Review

No abstract provided.


Federal Taxation - Accumulated Earnings Tax - The Quantum Of Tax Avoidance Purpose Required - United States V. Donruss, 89 S. Ct. 501 (1969), Robert S. Parker Jr. May 1969

Federal Taxation - Accumulated Earnings Tax - The Quantum Of Tax Avoidance Purpose Required - United States V. Donruss, 89 S. Ct. 501 (1969), Robert S. Parker Jr.

William & Mary Law Review

No abstract provided.


Federal Taxation - Professional Service Corporation - Corporate Versus Partnership Statute - Empey V. United States, __ F. 2d __ (10th Cir. 1969)., Haldane Robert Mayer May 1969

Federal Taxation - Professional Service Corporation - Corporate Versus Partnership Statute - Empey V. United States, __ F. 2d __ (10th Cir. 1969)., Haldane Robert Mayer

William & Mary Law Review

No abstract provided.


Non-Business Guaranty Loss: Ordinary Or Capital Deduction, Robert S. Parker Jr. Mar 1969

Non-Business Guaranty Loss: Ordinary Or Capital Deduction, Robert S. Parker Jr.

William & Mary Law Review

No abstract provided.


Book Review Of Items Of Gross Income, Emeric Fischer Dec 1968

Book Review Of Items Of Gross Income, Emeric Fischer

William & Mary Law Review

No abstract provided.


Simplification And Equity As Goals Of Tax Policy, Stanley S. Surrey, Gerard M. Brannon May 1968

Simplification And Equity As Goals Of Tax Policy, Stanley S. Surrey, Gerard M. Brannon

William & Mary Law Review

No abstract provided.


The Reincorporation Problem In Subchapter C. A Question Of Semantics?, R. P. Hertzog May 1968

The Reincorporation Problem In Subchapter C. A Question Of Semantics?, R. P. Hertzog

William & Mary Law Review

No abstract provided.


Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen May 1968

Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen

William & Mary Law Review

No abstract provided.


The Treatment Of Income & Deductions In The Case Of Controlled Or Related Entities, William H. Westphal May 1968

The Treatment Of Income & Deductions In The Case Of Controlled Or Related Entities, William H. Westphal

William & Mary Law Review

No abstract provided.


Tax Legislation Of 1966, John E. Donaldson Mar 1967

Tax Legislation Of 1966, John E. Donaldson

William & Mary Law Review

No abstract provided.


Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer Jan 1964

Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer

William & Mary Law Review

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.


The New "Subpart F" Foreign Income Provisions Of The Internal Revenue Code, Rexford R. Cherryman Apr 1963

The New "Subpart F" Foreign Income Provisions Of The Internal Revenue Code, Rexford R. Cherryman

William & Mary Law Review

No abstract provided.


The Reconstruction Of Net Income Under § 446(B) Of The Internal Revenue Code, John J. Harrington Apr 1963

The Reconstruction Of Net Income Under § 446(B) Of The Internal Revenue Code, John J. Harrington

William & Mary Law Review

No abstract provided.


Tax Planning For The Hobby Enthusiast, Daniel U. Livermore Jr. Mar 1962

Tax Planning For The Hobby Enthusiast, Daniel U. Livermore Jr.

William & Mary Law Review

No abstract provided.


The Civil Aspects Of The Net Worth Method, Richard D. Schwab Oct 1961

The Civil Aspects Of The Net Worth Method, Richard D. Schwab

William & Mary Law Review

No abstract provided.


The Deductability Of Moving Expenses And Investigatory Expenses, Bernard Goldstein Oct 1961

The Deductability Of Moving Expenses And Investigatory Expenses, Bernard Goldstein

William & Mary Law Review

No abstract provided.


Federal Income Taxation: Meals And Lodging Furnished For The Convenience Of The Employer - Two Sequels To The Boykin Case, Rexford R. Cherryman Oct 1961

Federal Income Taxation: Meals And Lodging Furnished For The Convenience Of The Employer - Two Sequels To The Boykin Case, Rexford R. Cherryman

William & Mary Law Review

No abstract provided.


Federal Income Taxation: Deductability Of Medical Expenses Which Are Also Personal Expenses, Ronald L. Buckwalter Oct 1961

Federal Income Taxation: Deductability Of Medical Expenses Which Are Also Personal Expenses, Ronald L. Buckwalter

William & Mary Law Review

No abstract provided.


Tax Effects Of Divorce, Marital Separation And Support Agreement, Lester I. Bowman Mar 1960

Tax Effects Of Divorce, Marital Separation And Support Agreement, Lester I. Bowman

William & Mary Law Review

No abstract provided.


Short Term Trusts, John William Hornsby Jr. Mar 1960

Short Term Trusts, John William Hornsby Jr.

William & Mary Law Review

No abstract provided.