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Full-Text Articles in Law

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.


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.


Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason Jan 2008

Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason

Faculty Publications

No abstract provided.


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.


Navigating Uncharted Waters: The New Charitable Entity Legislation, Robert L. Thalhimer, Michele A. W. Mckinnon Nov 2007

Navigating Uncharted Waters: The New Charitable Entity Legislation, Robert L. Thalhimer, Michele A. W. Mckinnon

William & Mary Annual Tax Conference

No abstract provided.


The Effects Of The Virginia Land Preservation Credit On Federal Taxable Income: Should The Right Hand Take From What The Left Hand Gave?, W. Eugene Seago Oct 2007

The Effects Of The Virginia Land Preservation Credit On Federal Taxable Income: Should The Right Hand Take From What The Left Hand Gave?, W. Eugene Seago

William & Mary Environmental Law and Policy Review

No abstract provided.


Congress's Tax Incentives Send Mixed Signals For Automobile Buyers: Should Americans Buy Gas Guzzlers Or Hybrids?, Bradley A. Ridlehoover Oct 2007

Congress's Tax Incentives Send Mixed Signals For Automobile Buyers: Should Americans Buy Gas Guzzlers Or Hybrids?, Bradley A. Ridlehoover

William & Mary Environmental Law and Policy Review

No abstract provided.


Why Pension Funding Matters, Eric D. Chason Jan 2007

Why Pension Funding Matters, Eric D. Chason

Faculty Publications

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.


Deferred Compensation Reform: Taxing The Fruit Of The Tree In Its Proper Season, Eric D. Chason Jan 2006

Deferred Compensation Reform: Taxing The Fruit Of The Tree In Its Proper Season, Eric D. Chason

Faculty Publications

Executive pensions (or deferred compensation) grabbed headlines after Enron's collapse and fresh concerns over ever-increasing executive pay. They also grabbed the attention of Congress, which reformed executive pensions legislatively in 2004 with ยง 409A of the Internal Revenue Code. Section 409A merely tightens and clarifies the doctrines that had already governed executive pensions, leaving the basic economics of executive pensions unchanged. Executives can still defer taxation on current compensation until actual payment is made in the future. Deferral still comes at the same price to the employer, namely the deferral of its deduction for the compensation expense. Thus, the timing ...


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.


Strategic Planning For The Closely Held Business -- Where To Go Beyond Bank Debt And Internal Growth, Arthur E. Cirulnick Nov 2002

Strategic Planning For The Closely Held Business -- Where To Go Beyond Bank Debt And Internal Growth, Arthur E. Cirulnick

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.


Final Minimum Distribution Rules, Louis A. Mezzullo Nov 2002

Final Minimum Distribution Rules, Louis A. Mezzullo

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.


Recent Developments In Federal Income Taxation, Ira B. Shepard, Martin J. Mcmahon Jr. Dec 2000

Recent Developments In Federal Income Taxation, Ira B. Shepard, Martin J. Mcmahon Jr.

William & Mary Annual Tax Conference

No abstract provided.


Investing For After-Tax Returns: An Overview, Anne B. Shumadine Dec 2000

Investing For After-Tax Returns: An Overview, Anne B. Shumadine

William & Mary Annual Tax Conference

No abstract provided.


Bad Drafting - A Case Study Of The Design And Implementation Of The Income Tax Subsidies For Education, Glenn E. Coven Oct 2000

Bad Drafting - A Case Study Of The Design And Implementation Of The Income Tax Subsidies For Education, Glenn E. Coven

Faculty Publications

No abstract provided.


Recent Federal Income Tax Developments, Ira B. Shepard Dec 1999

Recent Federal Income Tax Developments, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


International Comity And The Foreign Tax Credit: Crediting Nonconforming Taxes, Glenn E. Coven Jan 1999

International Comity And The Foreign Tax Credit: Crediting Nonconforming Taxes, Glenn E. Coven

Faculty Publications

No abstract provided.


Selected Recent Federal Income Tax Developments, Ira B. Shepard Dec 1998

Selected Recent Federal Income Tax Developments, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Practice Before The Irs After The Restructuring And Reform Act, T. Keith Fogg, Robert E. Lee Dec 1998

Practice Before The Irs After The Restructuring And Reform Act, T. Keith Fogg, Robert E. Lee

William & Mary Annual Tax Conference

No abstract provided.