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Articles 1 - 30 of 126
Full-Text Articles in Law
R&D Tax Incentives--Growth Panacea Or Budget Trojan Horse?, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
R&D Tax Incentives--Growth Panacea Or Budget Trojan Horse?, Stephen E. Shay, J. Clifton Fleming Jr., Robert J. Peroni
Faculty Scholarship
No abstract provided.
Two Cheers For The Foreign Tax Credit, Even In The Beps Era, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Two Cheers For The Foreign Tax Credit, Even In The Beps Era, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Faculty Scholarship
Reform of the U.S. international income taxation system has been a hotly debated topic for many years. The principal competing alternatives are a territorial or exemption system and a worldwide system. For reasons summarized in this article, we favor worldwide taxation if it is real worldwide taxation – i.e., a non-deferred U.S. tax is imposed on all foreign income of U.S. residents at the time the income in earned. This approach is not acceptable, however, unless the resulting double taxation is alleviated. The longstanding U.S. approach for handling the international double taxation problem is a foreign tax credit limited to …
Tax Benefits Of Government-Owned Marijuana Stores, Benjamin Leff
Tax Benefits Of Government-Owned Marijuana Stores, Benjamin Leff
Articles in Law Reviews & Other Academic Journals
This Article is the first to address whether independent governmental affiliates that sell marijuana are exempt from federal income tax under section 115 of the Internal Revenue Code. It argues that such entities should easily pass the IRS's current interpretation of the three requirements for tax-exemption under section 115: (i) that exempt income be derived from "the exercise of any essential governmental function"; (ii) that such income "accru[e] to a State or any political subdivision thereof"; and (iii) that the income "not serve private interests[.]" In addition, this Article argues that though selling marijuana is illegal under federal law, that …
Giving Credit Where Credit Is Due: Reducing Inequality With A Progressive State Tax Credit, Eric Kades
Giving Credit Where Credit Is Due: Reducing Inequality With A Progressive State Tax Credit, Eric Kades
Faculty Publications
No abstract provided.
Country By Country Reporting And Corporate Privacy: Some Unanswered Questions, Reuven S. Avi-Yonah
Country By Country Reporting And Corporate Privacy: Some Unanswered Questions, Reuven S. Avi-Yonah
Articles
Corporate privacy is an oxymoron. Individuals have a right to privacy, which the Supreme Court has recognized at least since Griswold v. Connecticut (1965). Warren and Brandeis’ famous defense of the right to privacy (1890) clearly applied only to individuals, because only individuals have the kind of feelings that are affected by invasions of privacy. Corporations are legal entities, and the concept of privacy does not apply to them, as the Supreme Court held in 1906. Thus, any objection to making corporate tax returns public cannot rest on the right to privacy. In fact, corporate returns were made public in …
Redistributive Taxation In The Modern World, Vincent Ooi
Redistributive Taxation In The Modern World, Vincent Ooi
Research Collection Yong Pung How School Of Law
Academic discussion of justice and taxation has focused on determining the moral limits of taxation. This article is concerned specifically with the moral limits on the redistributivity of taxation. Rawlsian principles enable us to determine the moral upper and lower bounds of redistribution through tax and transfer systems. However, major changes since Rawls and Nozick prompt a re-examination of these bounds in the modern context. Increased affluence means that for many societies the worst-off citizens are well-off in absolute terms. Increased immigration and emigration means that the classical model of a closed society is now obsolete. I consider the basis …
Can A Cost Sharing Arrangement Prevent A Tax Shelter Label?, Jeffrey M. Kadet
Can A Cost Sharing Arrangement Prevent A Tax Shelter Label?, Jeffrey M. Kadet
Articles
In connection with an ongoing effort of the government to examine certain Microsoft documents, the government on October 12, 2016, stated in a filed document that one of the transactions at issue is "unquestionably" a tax shelter for purposes of section 7525. The significance of that is in whether some written communications should be protected from IRS scrutiny by the section 7525 confidentiality privilege that may apply to tax advice between a taxpayer and tax practitioners. Under section 7525(b)(2), written communications will not qualify if they are "in connection with the promotion of the direct or indirect participation of the …
Brief Of Interested Law Professors As Amici Curiae Supporting Petitioner, Edward A. Zelinsky
Brief Of Interested Law Professors As Amici Curiae Supporting Petitioner, Edward A. Zelinsky
Amicus Briefs
Amici curiae are 14 professors of law who have devoted much of their teaching and research to the area of state taxes and the role of state tax policy in our federal system. The names and affiliations (for identification purposes only) of amici are included in an addendum to this brief. The amici are concerned with the effect of this Court’s dormant Commerce Clause jurisprudence on the development of fair and efficient state tax systems. No decision of this Court has had more effect on state sales and use tax systems than Quill Corporation v. North Dakota. We believe …
Gcc Vat: The Intra-Gulf Trade Problem, Richard Thompson Ainsworth, Musaad Alwohaibi
Gcc Vat: The Intra-Gulf Trade Problem, Richard Thompson Ainsworth, Musaad Alwohaibi
Faculty Scholarship
It seems reasonably clear that by January 1, 2018 events will be set in motion for the adoption of a community-wide 5% value added tax (VAT) in the six Member States of the Gulf Cooperation Council (GCC).
The GCC’s Framework VAT document is expected to be published by the end of October 2016. One of the clearest, consistently placed observations is that the Arabian VATs will be destination-based and modeled on a European credit-invoice design. Intra-Gulf business-to-business (B2B) transactions will be effectively zero-rated by the supplier, and the buyer’s VAT will be directed to the destination jurisdiction. It is not …
2016 Tax Conference Speakers
William & Mary Annual Tax Conference
No abstract provided.
Understanding Section 704(C) (Powerpoint), Brian J. O'Connor
Understanding Section 704(C) (Powerpoint), Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Understanding Targeted Allocations (Powerpoint), Brian J. O'Connor
Understanding Targeted Allocations (Powerpoint), Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Understanding Targeted Allocations (Powerpoint), Brian J. O'Connor
Understanding Targeted Allocations (Powerpoint), Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
What To Do Today With The New Partnership (And Llc) Audit Rules, Craig D. Bell, Steven R. Schneider
What To Do Today With The New Partnership (And Llc) Audit Rules, Craig D. Bell, Steven R. Schneider
William & Mary Annual Tax Conference
No abstract provided.
Tax Credits Basics & Update--Historic Tax Credits And New Markets Tax Credits (Powerpoint), Stephen M. Sharkey
Tax Credits Basics & Update--Historic Tax Credits And New Markets Tax Credits (Powerpoint), Stephen M. Sharkey
William & Mary Annual Tax Conference
No abstract provided.
Real Estate Methods And Credits: A Summary Of Recent Developments And Strategies (Powerpoint), Brandon C. Carlton
Real Estate Methods And Credits: A Summary Of Recent Developments And Strategies (Powerpoint), Brandon C. Carlton
William & Mary Annual Tax Conference
No abstract provided.
Recent Tax Developments In Virginia: 2015-2016, Craig D. Bell, William L.S Rowe, Emily J. Winbigler
Recent Tax Developments In Virginia: 2015-2016, Craig D. Bell, William L.S Rowe, Emily J. Winbigler
William & Mary Annual Tax Conference
No abstract provided.
Background And Framework Of Compensatory Llc Interests (Powerpoint), Brian J. O'Connor
Background And Framework Of Compensatory Llc Interests (Powerpoint), Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Let My Trustees Go! Planning To Minimize Or Eliminate Virginia And Other State Income Taxes On Trusts (Powerpoint), Richard W. Nenno
Let My Trustees Go! Planning To Minimize Or Eliminate Virginia And Other State Income Taxes On Trusts (Powerpoint), Richard W. Nenno
William & Mary Annual Tax Conference
No abstract provided.
Aligning The Stars- Estate Planning For Entrepreneurs In Interesting Times, Stefan F. Tucker, Tammara Langlieb
Aligning The Stars- Estate Planning For Entrepreneurs In Interesting Times, Stefan F. Tucker, Tammara Langlieb
William & Mary Annual Tax Conference
No abstract provided.
Tax Reform In The Next Administration (Outline), Evan M. Migdail
Tax Reform In The Next Administration (Outline), Evan M. Migdail
William & Mary Annual Tax Conference
No abstract provided.
Let's Look At The Big Picture: Partnership Compensation Issues From The Partnership And Benefits Perspective, Elizabeth E. Drigotas
Let's Look At The Big Picture: Partnership Compensation Issues From The Partnership And Benefits Perspective, Elizabeth E. Drigotas
William & Mary Annual Tax Conference
No abstract provided.
Structuring (And Drafting) Joint Venture Agreements (Powerpoint), Steven R. Schneider, Brian J. O'Connor
Structuring (And Drafting) Joint Venture Agreements (Powerpoint), Steven R. Schneider, Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Purchase And Sale Ofllc And S Corp Targets (Powerpoint), Robert G. Mcelroy, William M. Richardson
Purchase And Sale Ofllc And S Corp Targets (Powerpoint), Robert G. Mcelroy, William M. Richardson
William & Mary Annual Tax Conference
No abstract provided.
Let My Trustees Go! Planning To Minimize Or Eliminate Virginia And Other State 12 Income Taxes On Trusts (Outline), Richard W. Nenno
Let My Trustees Go! Planning To Minimize Or Eliminate Virginia And Other State 12 Income Taxes On Trusts (Outline), Richard W. Nenno
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Business Entity, C. Wells Hall Iii
Choice Of Business Entity, C. Wells Hall Iii
William & Mary Annual Tax Conference
No abstract provided.
Tax Status: Employee Vs Independent Contractor And Employee Vs Partner, Kurt L.P. Lawson
Tax Status: Employee Vs Independent Contractor And Employee Vs Partner, Kurt L.P. Lawson
William & Mary Annual Tax Conference
No abstract provided.
Federal Tax Update (Powerpoint), Stephen L. Owen
Federal Tax Update (Powerpoint), Stephen L. Owen
William & Mary Annual Tax Conference
No abstract provided.