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Full-Text Articles in Law

The Enigma Of Wynne, Edward A. Zelinsky Apr 2016

The Enigma Of Wynne, Edward A. Zelinsky

William & Mary Business Law Review

The five-justice Wynne majority used that case to make a major statement about the dormant Commerce Clause. In many respects, Wynne is an enigma that perpetuates an inherent problem of the Court’s dormant Commerce Clause doctrine: the Court declares some ill-defined taxes as unconstitutionally discriminatory because they encourage in-state investment, while other economically equivalent taxes and government programs that similarly encourage intrastate economic activity are apparently acceptable under the dormant Commerce Clause.

Wynne is thus more important than the immediate situation it addresses, and will have consequences beyond the immediate circumstances it addresses. A decision as enigmatic as it ...


Federal Tax Update, Stephen L. Owen Nov 2015

Federal Tax Update, Stephen L. Owen

William & Mary Annual Tax Conference

No abstract provided.


Net Investment Income Tax Planning, Jeanne M. Sullivan Nov 2014

Net Investment Income Tax Planning, Jeanne M. Sullivan

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments & Tax Planning For High Income Taxpayers, Cameron N. Cosby, Brian J. O'Connor Nov 2013

Recent Developments & Tax Planning For High Income Taxpayers, Cameron N. Cosby, Brian J. O'Connor

William & Mary Annual Tax Conference

No abstract provided.


A Tax Hike Liberals And Conservatives Should Both Like, Nathan B. Oman Jan 2013

A Tax Hike Liberals And Conservatives Should Both Like, Nathan B. Oman

Popular Media

No abstract provided.


Extending The Taxation-Of-Risk Model To Timing Options And Marked-To-Market Taxes, Eric D. Chason Jan 2013

Extending The Taxation-Of-Risk Model To Timing Options And Marked-To-Market Taxes, Eric D. Chason

Faculty Publications

No abstract provided.


A Primer On Us. Taxation Of International Transactions (Slides), William B. Sherman Nov 2012

A Primer On Us. Taxation Of International Transactions (Slides), William B. Sherman

William & Mary Annual Tax Conference

No abstract provided.


A Primer On Us. Taxation Of International Transactions (Outline), William B. Sherman Nov 2012

A Primer On Us. Taxation Of International Transactions (Outline), William B. Sherman

William & Mary Annual Tax Conference

No abstract provided.


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.


Federal Tax Update: The Current Situation And The Prospects For Reform (Slides), Harry L. Gutman Nov 2012

Federal Tax Update: The Current Situation And The Prospects For Reform (Slides), Harry L. Gutman

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2011

Recent Developments In Federal Income Taxation, Ira B. Shepard

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 nuts and ...


Taxation, Pregnancy, And Privacy, Bridget J. Crawford Feb 2010

Taxation, Pregnancy, And Privacy, Bridget J. Crawford

William & Mary Journal of Race, Gender, and Social Justice

This Article frames a discussion of surrogacy within the context of existing income tax laws. A surrogate receives money for carrying and bearing a child. This payment is income by any definition, even if the surrogacy contract recites that it is a “reimbursement.” Cases and rulings on the income tax consequences of the sale of blood and human breast milk, as well as analogies to situations in which people are paid to wear advertising on their bodies, support the conclusion that a surrogate recognizes taxable income, although the Internal Revenue Service has never stated so. For tax purposes, the reproductive ...


The Virginia Historic Tax Credit Funds Case And The Uncertain Federal Income Tax Treatment Of State Tax Credits, William F. Machen Nov 2009

The Virginia Historic Tax Credit Funds Case And The Uncertain Federal Income Tax Treatment Of State Tax Credits, William F. Machen

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2009

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2008

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


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.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2007

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2006

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Federal Income Tax Examinations Of Pass-Through Entities, Gerald A. Kafka, Kari M. Larson Nov 2006

Federal Income Tax Examinations Of Pass-Through Entities, Gerald A. Kafka, Kari M. Larson

William & Mary Annual Tax Conference

No abstract provided.


Class Warfare 1988-2005 Over Top Individual Income Tax Rates: Teeter-Totter From Soak-The-Rich To Robin-Hood-In-Reverse, John W. Lee Jan 2006

Class Warfare 1988-2005 Over Top Individual Income Tax Rates: Teeter-Totter From Soak-The-Rich To Robin-Hood-In-Reverse, John W. Lee

Faculty Publications

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2005

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Income Tax Issues For Lessors And Lessees (Slides), Susan T. Edlavitch, Robert D. Schachat Nov 2005

Income Tax Issues For Lessors And Lessees (Slides), Susan T. Edlavitch, Robert D. Schachat

William & Mary Annual Tax Conference

No abstract provided.


Income Tax Issues For Lessors And Lessees, Susan T. Edlavitch, Robert D. Schachat Nov 2005

Income Tax Issues For Lessors And Lessees, Susan T. Edlavitch, Robert D. Schachat

William & Mary Annual Tax Conference

No abstract provided.


The Capital Gains "Sieve" And The "Farce" Of Progressivity 1921-1986, John W. Lee Jan 2005

The Capital Gains "Sieve" And The "Farce" Of Progressivity 1921-1986, John W. Lee

Faculty Publications

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2004

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard, Mary Ann Cohen Nov 2003

Recent Developments In Federal Income Taxation, Ira B. Shepard, Mary Ann Cohen

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Nov 2002

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Dec 2001

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


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.