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Articles 1 - 23 of 23
Full-Text Articles in Law
Imposition Of Impact Fees After Volusia County V. Aberdeen: Has Florida Finally Reached Its State And Federal Constitutional Limit?, Shari Cruse
Golden Gate University Law Review
This Note first discusses the difference between the assessment of fees and the imposition of taxes, and provides a brief history of the development, limitations and expansion of impact fees in Florida. Parts III and IV of this Note provide an outline of the facts and procedural history of Volusia County v. Aberdeen, including the initial lawsuit filed by Aberdeen, L.P., and other leading Florida case law on assessment and impact fees. Part V of this Note discusses the Florida Supreme Court's rationale for upholding the lower court's ruling in favor of Aberdeen, L.P., which will then be comparatively analyzed …
The Amalgamating Reorganization Provisions: The Asymmetry In Treatment Of Forward And Reverse Triangular Mergers And Other Problems, Tad Ravazzini
The Amalgamating Reorganization Provisions: The Asymmetry In Treatment Of Forward And Reverse Triangular Mergers And Other Problems, Tad Ravazzini
Golden Gate University Law Review
This comment will discuss the amalgamating reorganizations generally (types A through C as well as some D's) and, specifically, triangular reorganizations. This comment will first provide an overview of the general requirements of the amalgamating reorganization provisions. It will then continue to the following topics: (1) a discussion of the Code's triangular reorganization provisions, giving attention to both forward and reverse triangular mergers; (2) an analysis of the asymmetry in treatment of triangular mergers based on whether they take the form of a forward or reverse triangular merger; (3) an exploration of the Congressional desire for tax-parity among the reorganization …
Department Of Revenue V. Kurth Ranch: The Expansion Of Double Jeopardy Jurisprudence Into Civil Tax Proceedings, Tad Ravazzini
Department Of Revenue V. Kurth Ranch: The Expansion Of Double Jeopardy Jurisprudence Into Civil Tax Proceedings, Tad Ravazzini
Golden Gate University Law Review
This summary first provides a brief overview of the Fifth Amendment's Double Jeopardy Clause. The overview will be followed by an analysis of the Supreme Court's expansion of double jeopardy application in United States v. Halper. The summary will then briefly analyze Montana's Dangerous Drug Tax Act. Finally, the summary will discuss the majority's reasoning in Kurth Ranch, and examine the three separate dissenting opinions.
Tax Law - In Re Kroy (Europe) Limited: Whether A Corporation May Amortize And Deduct Loan Fees Incurred In Financing A Stock Redemption, Robert G. Lorndale Jr.
Tax Law - In Re Kroy (Europe) Limited: Whether A Corporation May Amortize And Deduct Loan Fees Incurred In Financing A Stock Redemption, Robert G. Lorndale Jr.
Golden Gate University Law Review
In In re Kroy (Europe) Limited,l the Ninth Circuit held that a corporation could amortize and deduct fees which it incurred in borrowing funds used to redeem stock under §162(a) of the Internal Revenue Code. Section 162(a) allows a corporation to deduct ordinary and necessary business expenses. Kroy required the court to decide whether §162(k) of the Internal Revenue Code, an exception to §162(a), applied to these fees and would preclude their deduction. Section 162(k) disallows deduction of any expenses incurred "in connection with" a stock redemption. The Ninth Circuit determined that §162(k) did not apply to the fees because …
Tax Law, James Thurston
Recent Developments In The Taxation Of Computer Software, Robert W. Mcgee
Recent Developments In The Taxation Of Computer Software, Robert W. Mcgee
Golden Gate University Law Review
Computer software has tax consequences both at the state and federal levels. At the state level, software might be subject to sales, use or property taxation if it is considered to be tangible personal property. On the federal level, software may qualify for the investment tax credit or research credit, also depending on tangibility. In the last few years, both state and federal courts and legislatures have rendered decisions and passed laws that have altered the taxability of computer software. This article summarizes those changes and attempts to spot a trend.
Tax Law, Matthew B. Krasner
Can The Internal Revenue Service Be Held Accountable For Its Administrative Conduct? The I.R.C. Section 7430 Fee Recovery Controversy, Dani Michele Miller
Can The Internal Revenue Service Be Held Accountable For Its Administrative Conduct? The I.R.C. Section 7430 Fee Recovery Controversy, Dani Michele Miller
Golden Gate University Law Review
No abstract provided.
Tax Law, William K. Peterson
When A Liquidating Corporation Distributes A Partnership Interest: The Problem Of Depreciation/Acrs Recapture, Twila Castellucci
When A Liquidating Corporation Distributes A Partnership Interest: The Problem Of Depreciation/Acrs Recapture, Twila Castellucci
Golden Gate University Law Review
This Note will discuss the tax consequences when a corporation liquidates and distributes its partnership interest to a shareholder. Included in this discussion will be an analysis of whether a corporation can avoid paying taxes on recapture income if it has not received any tax benefit from deductions subject to recapture.
Summaries: Tax Law, Blaise Curet
Summaries: Tax Law, Blaise Curet
Golden Gate University Law Review
No abstract provided.
Tax Law, Stacy Snowman
Tax Law, Laurie Ann Hedrich
Thoroughbred Horse Racing And Breeding As A Tax Sheltered Investment: Recent Tax Law Developments, Joel B. Turner
Thoroughbred Horse Racing And Breeding As A Tax Sheltered Investment: Recent Tax Law Developments, Joel B. Turner
Golden Gate University Law Review
This comment will first discuss principal tax shelter methods in general terms and then address the effects of recent tax legislation on tax-sheltered investments. Finally, the application of the current rules to hypothetical thoroughbred tax-sheltered investments will be undertaken to illustrate some of the options available to investors.
Taxation, Jeff Kirk
Inequity & Economics: Federal Income, Gift And Estate Tax Treatment Of De Facto Families, Michael Zaidel
Inequity & Economics: Federal Income, Gift And Estate Tax Treatment Of De Facto Families, Michael Zaidel
Golden Gate University Law Review
Disparate tax treatment of married couples in common law vis-a-vis community property states led to remedial congressional action a generation ago. The current inequity lies between married and unmarried couples. Correcting that imbalance will again require congressional action. Nevertheless, this Comment argues that precedent exists for judicial remedy of some of the inequitable tax burdens of the unmarried couple. Tax planning is beyond the scope of this Comment, but suggestions will be offered. Property rights and contract formation are treated only to the extent of their tax ramifications.
Nonrecourse Financing And Tax Shelter Abuse: The Crane Doctrine Before And After The At Risk Provisions, Michael Gurwitz
Nonrecourse Financing And Tax Shelter Abuse: The Crane Doctrine Before And After The At Risk Provisions, Michael Gurwitz
Golden Gate University Law Review
This Comment will examine the history of nonrecourse financing and tax shelters from the fabled Crane holding to the new reality of the ARP. This will be done by dividing the Comment into four parts. Part I will discuss the period preceding the passage of the Tax Reform Act of 1976, focusing on the Crane doctrine and subsequent attempts by the Internal Revenue Service (IRS) to define and limit the use of nonrecourse debt. Part II will highlight the factors that contributed to the growing abuse of tax shelters. Part III, in general terms, will examine the statutory scheme of …
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Golden Gate University Law Review
No abstract provided.
Taxation, Carol M. Kingsley, Helen Rowland Martin
Taxation, Carol M. Kingsley, Helen Rowland Martin
Golden Gate University Law Review
No abstract provided.
Taxation, Marianne K. Tomecek
Taxation, Martin T. Murray
Medical Expense Deductions Under Section 213 Of The Internal Revenue Code Of 1954: The Definition Of "Medical Care", Dale A. Affonso
Medical Expense Deductions Under Section 213 Of The Internal Revenue Code Of 1954: The Definition Of "Medical Care", Dale A. Affonso
Golden Gate University Law Review
No abstract provided.
Taxation, George Mac Vogelei