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Full-Text Articles in Law
Unilateral Responses To Tax Treaty Abuse: A Functional Approach, Omri Y. Marian
Unilateral Responses To Tax Treaty Abuse: A Functional Approach, Omri Y. Marian
UF Law Faculty Publications
Recent years have seen a dramatic increase in the attention given to abusive tax schemes that take advantage of bilateral tax treaties. The ensuing discourse tends to view potential responses to treaty abuses as a hierarchical set of options, gradually escalating, in which treaty termination is a last resort option. This article argues that the hierarchical view of unilateral responses to treaty abuse is misguided. Unilateral responses to treaty-based abuse are not hierarchically ordered. Rather, the approach to treaty abuse is (and should be) functional, adopting specific types of unilateral responses based on the type of treaty abuse at issue. …
Recent Developments In Federal Income Taxation: The Year 2009, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Recent Developments In Federal Income Taxation: The Year 2009, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
UF Law Faculty Publications
This article 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 2008 – and sometimes a little farther back in time if the authors 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are discussed to the extent that …
Recent Developments In Federal Income Taxation: The Year 2008, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Recent Developments In Federal Income Taxation: The Year 2008, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
UF Law Faculty Publications
This article 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 2008 - and sometimes a little farther back in time if the authors 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are discussed to the extent that …
Recent Developments In Federal Income Taxation: The Year 2007, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Recent Developments In Federal Income Taxation: The Year 2007, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
UF Law Faculty Publications
This recent developments outline discusses, and provides context to understand the significance of, the most importnat judicial decisions and administrative rulings and regulations and promulgated by the Internal Revenue Service and Treasury Department during 2007- and sometimes a little farther back in time if we find the item particulary humourous or outrageous. Most Treasury Regulations, houever, are so complex that they cannot be dicussed in detail and, anyway, only a devout masochist would read them all the way through; just the basic topic and fundamental principles are highlighted. Admendmentsto the Internal Revenue Code generally are not dicussed except to the …
Recent Developments In Federal Income Taxation: The Year 2006, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation: The Year 2006, Ira B. Shepard, Martin J. Mcmahon Jr.
UF Law Faculty Publications
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 2006 - 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …
Recent Developments In Federal Income Taxation: The Year 2005, Martin J. Mcmahon Jr., Ira B. Shepard
Recent Developments In Federal Income Taxation: The Year 2005, Martin J. Mcmahon Jr., Ira B. Shepard
UF Law Faculty Publications
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 2005 - 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …
Recent Developments In Federal Income Taxation: The Year 2004, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation: The Year 2004, Ira B. Shepard, Martin J. Mcmahon Jr.
UF Law Faculty Publications
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 2004 - 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …
Recent Developments In Federal Income Taxation: The Year 2003, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation: The Year 2003, Ira B. Shepard, Martin J. Mcmahon Jr.
UF Law Faculty Publications
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 2003 - 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …
Recent Developments In Federal Income Taxation: The Year 2002, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation: The Year 2002, Ira B. Shepard, Martin J. Mcmahon Jr.
UF Law Faculty Publications
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 2002 - 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …
Recent Developments In Federal Income Taxation: The Year 2001, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation: The Year 2001, Ira B. Shepard, Martin J. Mcmahon Jr.
UF Law Faculty Publications
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 2001 - 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …
Recent Developments In Federal Income Taxation: The Year 2000, Ira B. Shepard, Martin J. Mcmahon Jr.
Recent Developments In Federal Income Taxation: The Year 2000, Ira B. Shepard, Martin J. Mcmahon Jr.
UF Law Faculty Publications
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 2000 - 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 fundamental principles are highlighted. Amendments to the Internal Revenue Code generally are not discussed except to …