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Articles 1 - 11 of 11
Full-Text Articles in Tax Law
Of More Than Usual Interest: The Taxing Problem Of Debt Principal, Charlene Luke
Of More Than Usual Interest: The Taxing Problem Of Debt Principal, Charlene Luke
UF Law Faculty Publications
Leverage is an essential but often troubling component of the U.S. market. The financial crisis highlighted the risks and complexity of a leverage web that includes flesh-and-blood people from all walks of life and paper people from all corners of the business and investment world. In the tax area, the potentially problematic incentive effects of interest deductibility have long engaged a wide array of tax commentators and policymakers. While interest deductibility rightly receives widespread scrutiny, a more comprehensive approach to leverage is needed. This Article focuses on the surprisingly complicated tax treatment of cash (and cash equivalent) borrowings. This Article …
Recent Developments In Federal Income Taxation: The Year 2010, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Recent Developments In Federal Income Taxation: The Year 2010, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Martin J. McMahon
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 the year 2010--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--unless one of us decides to go nuts and spend several pages writing …
Recent Developments In Federal Income Taxation: The Year 2012, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Recent Developments In Federal Income Taxation: The Year 2012, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Martin J. McMahon
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 the most recent twelve months - 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 - unless one of us decides to go …
Income Tax Considerations In The Transition To A Professional Corporation, Harvey Dunn
Income Tax Considerations In The Transition To A Professional Corporation, Harvey Dunn
Akron Law Review
[T]he tax considerations in the formation and operation of a professional corporation are numerous and, unfortunately, there are many areas which lack definite guidelines so as to enable the practitioner to give as definite an answer as he would like to. However, as with any new area of tax law, it will take time, decisions and rulings to develop what one may term as reasonable guidelines for reaching a conclusion. In the meantime, there is little doubt that with careful planning in the formative stages and close observation of the operation of a professional corporation, the risk of problems with …
Federal Income Tax Developments: 1975
Federal Income Tax Developments: 1975
Akron Law Review
FEDERAL INCOME TAX DEVELOPMENTS: 1975 is the third of an annual series of articles to be published in the Winter Issue of the Akron LAW REVIEW. The thrust of this article is not only to identify the new developments, but also to trace these concepts through their formative stages. The area of concentration for this article includes cases decided through September 30, 1975. Given the volatile nature of taxation, it is crucial for the practitioner in this field to remain current with the changes which have occurred during the tax year. The purpose of this article is to highlight for …
Federal Income Tax Developments: 1977
Federal Income Tax Developments: 1977
Akron Law Review
The thrust of this article is not only to identify the new developments, but also to trace these concepts through their formulative changes. This article covers the new developments in the case law including those cases and rulings implementing the Tax Reform Act of 1976.
Federal Income Tax Developments: 1978
Federal Income Tax Developments: 1978
Akron Law Review
FEDERAL INCOME TAX DEVELOPMENTS: 1978 is the sixth of an annual series of articles to be published in the AKRON LAW REVIEW. The scope of this survey is limited to the substantive developments in the field of income taxation. The thrust of this article is not only to identify new developments, but also to trace these concepts through their formulative changes.
Unreasonable Compensation In The Professional Corporation, Vincent J. Falcone
Unreasonable Compensation In The Professional Corporation, Vincent J. Falcone
Akron Law Review
This comment will discuss the federal income tax issue of unreasonable compensation as it affects the incorporated professional. Discussion will first center on the modus operandi of the professional corporation, and how the compensation issue arises. Unreasonable compensation will then be defined and explained in that context. Next, the actual considerations used in determining whether compensation is excessive or not will be discussed. Then, the additional requirement that the remuneration be compensation in fact, and not a return on investment, will be investigated. The applicability of the 50% maximum tax on personal service income will also be analyzed. Finally, some …
Federal Income Tax Developments: 1979
Federal Income Tax Developments: 1979
Akron Law Review
The scope of this survey is limited to the substantive developments in the field of income taxation. The thrust of this article is not only to identify new developments, but also to trace these concepts through their formulative changes
Federal Income Tax Developments: 1980
Federal Income Tax Developments: 1980
Akron Law Review
The scope of this survey is limited to the substantive developments in the field of income taxation. The thrust of this article is not only to identify new developments, but also to trace these concepts through their formulative changes.
Taxing The Unheavenly Chorus: Why Section 501(C)(6) Trade Associations Are Undeserving Of Tax Exemption, Philip Hackney
Taxing The Unheavenly Chorus: Why Section 501(C)(6) Trade Associations Are Undeserving Of Tax Exemption, Philip Hackney
Articles
Our federal, state, and local governments provide a subsidy that enhances the political voice of business interests. This article discusses the federal subsidy for business interests provided through the Internal Revenue Code (“Code”) and argues why we should end that subsidy. Under the same section that provides exemption from income tax for charitable organizations, the Code also exempts nonprofit organizations classified as “business leagues, chambers of commerce, real-estate boards, boards of trade, or professional football leagues.” Theory supporting tax exemption states that we should subsidize nonprofit organizations that provide goods or services that are undersupplied by the market. A charitable …