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Common Misconceptions: The Function And Framework Of "Trade Or Business Within The United States", Nancy H. Kaufman
Common Misconceptions: The Function And Framework Of "Trade Or Business Within The United States", Nancy H. Kaufman
Vanderbilt Journal of Transnational Law
In this Article, Professor Kaufman examines the administrative and jurisdictional functions of the Internal Revenue Code's term "trade or business within the United States" in the taxation of foreign persons' income and the existing framework established for the term's interpretation. The author contends that the courts, by relying on two common misconceptions of the term, have made the term's application unpredictable. The author further believes that defining the term according to its functions would serve United States tax policy and economic interests. This definition would focus primarily on facts indicating an ongoing commitment to participation the United States economy. The …
Case Digest, Journal Staff
Case Digest, Journal Staff
Vanderbilt Journal of Transnational Law
Case Digest
1. ADMINISTRATIVE
NON-VESSEL-OPERATING COMMON CARRIERS HAVE BURDEN OF PROOF TO JUSTIFY THE REASONABLENESS OF PROPOSED RATE INCREASE IN A FEDERAL MARITIME COMMISSION PROCEEDING
2. ADMIRALTY
COMPARATIVE NEGLIGENCE STANDARD APPLICABLE TO THE CANAL ZONE COMPANY DOES NOT SUPERSEDE THE RULE OF DIVIDED DAMAGES BETWEEN VESSELS
FAILURE TO OBEY COMMANDS OF SHIP MASTER BECAUSE OF VOLUNTARY INTOXICATION CONSTITUTES WILLFUL DISOBEDIENCE
PREJUDGMENT INTEREST FROM DATE OF JUDICIAL DEMAND IS PROPER WHEN ORIGINAL ACTION AT LAW Is CHANGED TO ADMIRALTY BY WITHDRAWAL OF JURY DEMAND
THE PERSONAL REPRESENTATIVE ALONE HAS STANDING TO BRING A WRONGFUL DEATH ACTION IN GENERAL MARITIME LAW
PERMITTING …