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Articles 1 - 30 of 61
Full-Text Articles in Law
Divorce: A Taxing Experience, Charles Edward Falk
Divorce: A Taxing Experience, Charles Edward Falk
William & Mary Annual Tax Conference
No abstract provided.
Statutory (Formerly Non-Statutory) Fringe Benefits: New Sec. 132, Jerry J. Mccoy
Statutory (Formerly Non-Statutory) Fringe Benefits: New Sec. 132, Jerry J. Mccoy
William & Mary Annual Tax Conference
No abstract provided.
Disposition Of The Corporation Or The Corporate Business, N. Jerold Cohen
Disposition Of The Corporation Or The Corporate Business, N. Jerold Cohen
William & Mary Annual Tax Conference
No abstract provided.
The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven
The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven
William & Mary Annual Tax Conference
No abstract provided.
Handling Tax Shelter Disputes And Litigation With The Irs, Mortimer Caplin
Handling Tax Shelter Disputes And Litigation With The Irs, Mortimer Caplin
William & Mary Annual Tax Conference
No abstract provided.
Modification Of Divorce Decrees By Virtue Of The 1984 Tax Amendments Relating To Dependency Exemptions, Roger M. Baron
Modification Of Divorce Decrees By Virtue Of The 1984 Tax Amendments Relating To Dependency Exemptions, Roger M. Baron
University of Arkansas at Little Rock Law Review
No abstract provided.
Tax Expenditures And Tax Reform, Allaire U. Karzon
Tax Expenditures And Tax Reform, Allaire U. Karzon
Vanderbilt Law Review
This Review will focus primarily on the conceptual issues affecting the composition of the tax expenditure list and their relevance to current proposals for new tax legislation. In this context,the tax expenditure theory has been preeminently successful in shaping tax reform. The Review will not delve into the other aspect of Surrey's thesis, which calls for executive and congressional action to alter the budget procedure by integrating direct spending programs with the indirect tax expenditure programs and by adopting one amalgamated budget for the purpose of controlling overall federal spending. This facet of the Surrey thesis has not yet gained …
Lawyer Beware: The Use Of Counsel's Statements As Evidence Against His Client In Tax Fraud Cases, Lawrence S. Feld, Leonard R. Rosenblatt
Lawyer Beware: The Use Of Counsel's Statements As Evidence Against His Client In Tax Fraud Cases, Lawrence S. Feld, Leonard R. Rosenblatt
Articles & Chapters
No abstract provided.
Taxation - Deficit Reduction Act Of 1984 - Treatment Of Loans With Below-Market Interest Rates (Section 172) Statute Note., Douglas A. Allison
Taxation - Deficit Reduction Act Of 1984 - Treatment Of Loans With Below-Market Interest Rates (Section 172) Statute Note., Douglas A. Allison
St. Mary's Law Journal
Abstract Forthcoming.
Federal Tax Liens—I.R.S. May Levy Upon The Entire Balance Of A Joint Bank Account When Delinquent Codepositor Has Right Of Withdrawal, David A. Smith
Federal Tax Liens—I.R.S. May Levy Upon The Entire Balance Of A Joint Bank Account When Delinquent Codepositor Has Right Of Withdrawal, David A. Smith
University of Arkansas at Little Rock Law Review
No abstract provided.
An Opportunity Missed: Armco, Inc. V. Hardesty, A Retreat From Economic Reality In Analysis Of State Taxes, C. James Judson, Susan G. Duffy
An Opportunity Missed: Armco, Inc. V. Hardesty, A Retreat From Economic Reality In Analysis Of State Taxes, C. James Judson, Susan G. Duffy
West Virginia Law Review
No abstract provided.
Container Corporation Of America V. Franchise Tax Board: The Supreme Court Encourages Apportionment Taxation, Laura J. Waterland
Container Corporation Of America V. Franchise Tax Board: The Supreme Court Encourages Apportionment Taxation, Laura J. Waterland
William & Mary Law Review
No abstract provided.
Tax Tips, Frank Doti
Jackson Reanalyzed: Preventing Tax-Free Escape Upon Transfer Of A Partnership Interest, Michael J. Baader
Jackson Reanalyzed: Preventing Tax-Free Escape Upon Transfer Of A Partnership Interest, Michael J. Baader
William & Mary Law Review
No abstract provided.
The Experience Of The Phillipines In Taxing Its Nonresident Citizens, Richard Pomp
The Experience Of The Phillipines In Taxing Its Nonresident Citizens, Richard Pomp
Faculty Articles and Papers
No abstract provided.
Survey Of The Law And Selected Issues Relating To The Deductibility Of Soil And Water Conservation Expenditures Under Section 175 Of The Internal Revenue Code, Lonnie R. Beard
Kentucky Law Journal
No abstract provided.
The Tax Effects Of A Shareholder's Post-Incorporation Sale Of Stock: A Reappraisal, Robert I. Keller
The Tax Effects Of A Shareholder's Post-Incorporation Sale Of Stock: A Reappraisal, Robert I. Keller
Faculty Scholarship
No abstract provided.
Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel S. Goldberg
Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel S. Goldberg
Faculty Scholarship
No abstract provided.
A Comparison Of The Merger And Acquisition Provisions Of Present Law With The Provisions In The Senate Finance Committee's Draft Bill, Samuel C. Thompson Jr.
A Comparison Of The Merger And Acquisition Provisions Of Present Law With The Provisions In The Senate Finance Committee's Draft Bill, Samuel C. Thompson Jr.
Journal Articles
No abstract provided.
Internal Revenue Code Section 7701(B): A More Certain Definition Of Resident, Rolf E. Kroll
Internal Revenue Code Section 7701(B): A More Certain Definition Of Resident, Rolf E. Kroll
Penn State International Law Review
The purpose of this Note is four-fold. First, it seeks to articulate the central concepts underlying taxation of nonresidents and residents. In so doing, the discussion endeavors to show the importance of section 7701(b) of the Internal Revenue Code. Second, it attempts to cancas the case law and pertinent regulations and rulings and highlight the ambiguities therein. Third, the discussion will address the essential features of section 7701(b) and illustrate Congress' new approach to the problem of determining resident status for aliens. Finally, the policy implications of 7701(b) are examined and suggestions for further improvement are made.
Computer Software And The Investment Tax Credit, 5 Computer L.J. 347 (1984), Robert W. Mcgee
Computer Software And The Investment Tax Credit, 5 Computer L.J. 347 (1984), Robert W. Mcgee
UIC John Marshall Journal of Information Technology & Privacy Law
No abstract provided.
To Hold Or Not To Hold: Magneson, Bolker, And Continuity Of Investment Under I.R.C. Section 1031, J. Martin Burke, Michael K. Friel
To Hold Or Not To Hold: Magneson, Bolker, And Continuity Of Investment Under I.R.C. Section 1031, J. Martin Burke, Michael K. Friel
UF Law Faculty Publications
This article examines the judicial and administrative development of the two holding requirements under the continuity of investment standards of section 1031 prior to decisions of the Tax Court and the Ninth Circuit in Magneson v. Commissioner and Bolker v. Commissioner, both of which expanded the boundaries of qualified holding and reemphasized the need for guidance from the Treasury or Congress on these issues. Next the article examines the subsequent impact of these decisions. Finally, the article suggests a standard to be followed in the future.
Attribution Of A Multinational Corporation's Net Income: The Position Of Unitary States Regarding Combined Reporting, William D. Dexter
Attribution Of A Multinational Corporation's Net Income: The Position Of Unitary States Regarding Combined Reporting, William D. Dexter
Vanderbilt Journal of Transnational Law
A complex and controversial aspect of state taxation of business income involves the attribution of a multinational corporation's (MNC's) net income. This Article examines the nature and scope of the controversy that stems from the conflicting views of states that promote a unitary taxation system, and MNCs as well as the Department of Treasury (Treasury) that oppose this position. Section IV illustrates why the unitary business principle is currently the only viable, fair, and feasible method available to the states for the geographical assignment of an MNC's net income. Section V analyzes the MNCs' arguments both against worldwide combined reporting …
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Articles
No abstract provided.
The Acquisitions Proposals And Their Effect On Corporations, Shareholders And Creditors: Reform Of Reorganizations And Liquidations, Peter L. Faber, John Andre Leduc
The Acquisitions Proposals And Their Effect On Corporations, Shareholders And Creditors: Reform Of Reorganizations And Liquidations, Peter L. Faber, John Andre Leduc
San Diego Law Review
Mr. Faber sets the stage for the debate on the need for reform of our present system by summarizing some basic principles of current law, together with the exceptions that developed over the years. Mr. Faber makes the case for re-examination of Subchapter C, as well as other portions of the tax law. Mr. LeDuc seeks a framework within which to construct a tentative answer to the question that this conference is about: must corporate and shareholder income be taxed complexly? Mr. LeDuc suggests that, in order to create a framework to analyze the necessity for complexity in taxation of …
Revenue Ruling 84-132: Sidelined, But Not Forgotten, Nina R. Murphy
Revenue Ruling 84-132: Sidelined, But Not Forgotten, Nina R. Murphy
University of Richmond Law Review
Virtually all colleges and universities have scholarship programs designed to support their athletic teams. The programs are generally in the form of membership clubs which are tax-exempt under section 501(c)(3) of the Internal Revenue Code and therefore eligible to receive donations which provide tax deductions to their patrons. The fact that an organization is an "eligible receiver," however, does not ensure that all payments to it are deductible. For example, the cost of football tickets is not deductible since the purchaser is receiving value for his payment.
Commments: Continuing Vitality Of The "Goods Or Services" Test, Wayne Michael Willoughby
Commments: Continuing Vitality Of The "Goods Or Services" Test, Wayne Michael Willoughby
University of Baltimore Law Review
The term "trade or business" is used frequently throughout the Internal Revenue Code, and the determination of whether a taxpayer's activities constitute a trade or business has a major impact on the applicable tax treatment. Unfortunately, no definition of trade or business is supplied in the Internal Revenue Code, the legislative history, or the Treasury Regulations. Consequently, the courts have been left this task and two different standards for determining trade or business status have emerged. In this comment, the author reviews the history of the term "trade or business, " examines the decisional law, and analyzes the two current …
Tax Policy For Post-Liberal Society: A Flat Tax Inspired Redefinition Of The Purpose And Ideal Structure Of A Progressive Income Tax, Charles O'Kelley
Tax Policy For Post-Liberal Society: A Flat Tax Inspired Redefinition Of The Purpose And Ideal Structure Of A Progressive Income Tax, Charles O'Kelley
Faculty Articles
A flat rate comprehensive federal income tax could be achieved by replacing graduated rates with a single rate that applies to all taxpayers, eliminating many currently available deductions and credits, and treating as taxable income types of economic gain presently excluded from the tax base. The fact that Congress is seriously considering such radical changes makes it appropriate for tax scholars to reconsider longheld beliefs about the ideal structure of an income tax. This article analyzes the characteristics and underlying rationale of a progressive flat rate comprehensive income tax and reconsiders the nature and purpose of a progressive income tax. …
Reading Tea Leaves: The Fifth Amendment And Tax Records, James G. Starkey
Reading Tea Leaves: The Fifth Amendment And Tax Records, James G. Starkey
Loyola University Chicago Law Journal
No abstract provided.