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Articles 1 - 19 of 19

Full-Text Articles in Tax Law

Tax Lawyers As Tax Insurance, Heather M. Field May 2019

Tax Lawyers As Tax Insurance, Heather M. Field

William & Mary Law Review

Transactional tax lawyers, by rendering tax opinions, provide a version of insurance to clients. This insurance is clearly incomplete, but by providing a tax opinion, a lawyer conditionally agrees to indemnify the client for at least part of the potential loss the client incurs if the favorable tax treatment described in the opinion is successfully challenged. Although insurance is not the primary function of transactional tax lawyers, and although this Article does not argue that tax opinions should be regulated as insurance, indemnification—a key element of insurance—is an important part of the economic relationship between a client and a lawyer …


Recent Developments In Virginia Taxation, Craig D. Bell Nov 2018

Recent Developments In Virginia Taxation, Craig D. Bell

William & Mary Annual Tax Conference

No abstract provided.


Understanding Section 704(C) (Powerpoint), Brian J. O'Connor Nov 2016

Understanding Section 704(C) (Powerpoint), Brian J. O'Connor

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 Nov 2016

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.


Negotiating Tax Provisions In Partnership And Llc Agreements, Robert G. Gottlieb, Brian J. O'Connor Nov 2014

Negotiating Tax Provisions In Partnership And Llc Agreements, Robert G. Gottlieb, Brian J. O'Connor

William & Mary Annual Tax Conference

No abstract provided.


Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen Nov 2014

Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen

William & Mary Annual Tax Conference

No abstract provided.


Tax Accounting Methods Considerations In Restructuring Transactions, Glenn Carrington, Kristine Mora Nov 2014

Tax Accounting Methods Considerations In Restructuring Transactions, Glenn Carrington, Kristine Mora

William & Mary Annual Tax Conference

No abstract provided.


The Economic Ambiguity (And Possible Irrelevance) Of Tax Transition Rules, Eric D. Chason Apr 2003

The Economic Ambiguity (And Possible Irrelevance) Of Tax Transition Rules, Eric D. Chason

Faculty Publications

No abstract provided.


Corporate Managers, Agency Costs, And The Rise Of Double Taxation, Steven A. Bank Oct 2002

Corporate Managers, Agency Costs, And The Rise Of Double Taxation, Steven A. Bank

William & Mary Law Review

No abstract provided.


"Tax Library" Resources For The Small To Medium Sized Cpa Or Law Firm - Roundtable Discussion, Michael L. Layman, Timothy H. Guare, J. Patrick Budd, Gregory W. Geisert Dec 2000

"Tax Library" Resources For The Small To Medium Sized Cpa Or Law Firm - Roundtable Discussion, Michael L. Layman, Timothy H. Guare, J. Patrick Budd, Gregory W. Geisert

William & Mary Annual Tax Conference

No abstract provided.


Who Should Be Entitled To Claim The New Education Credits?, Glenn E. Coven Jan 1999

Who Should Be Entitled To Claim The New Education Credits?, Glenn E. Coven

Faculty Publications

Professor Coven believes that the education assistance provisions enacted in 1997, while long overdue, were ill-considered and poorly constructed. Focusing on what should have been the simple question of who is entitled to claim an education tax credit, this report illustrates the harm that inadequate drafting produces. While section 25A appeared to deny a credit to a dependent child, an unfair and unwise result, the proposed regulations allow parents to shift the credit to their children but only on the forfeiture of the deduction for the personal exemption. That rule, says Coven, imposes a harsh penalty on low and middle-income …


Simplified Entity Classification Under The Final Check-The-Box Regulations, Roger F. Pillow, John G. Schmalz, Samuel P. Starr Dec 1997

Simplified Entity Classification Under The Final Check-The-Box Regulations, Roger F. Pillow, John G. Schmalz, Samuel P. Starr

William & Mary Annual Tax Conference

No abstract provided.


Tax Issues In Divorce, Marjorie A. O'Connell Dec 1996

Tax Issues In Divorce, Marjorie A. O'Connell

William & Mary Annual Tax Conference

No abstract provided.


Incriminatory Effects Of Compliance With Irs Subpoenas For Personal Documents: An Analysis Of Current Approaches, Leah A. Kahl Dec 1996

Incriminatory Effects Of Compliance With Irs Subpoenas For Personal Documents: An Analysis Of Current Approaches, Leah A. Kahl

William & Mary Bill of Rights Journal

This Note argues that creating a tax-crime exception to the privilege against self-incrimination countervenes both the language and the spirit of the Fifth Amendment. This Note further argues that the Ninth Circuit's creation of a tax crime-exception stemmed from a misinterpretation of precedent.

This Note describes the tax system and structure of the Internal Revenue Service (IRS), including its investigatory powers. The relationship between the IRS and the Department of Justice is discussed to ascertain the incriminatory effects of taxpayers' disclosures. A Ninth Circuit district court case, United States v. Troescher, is used as a framework for analyzing the Ninth …


The Year In Review: A Discussion Of Significant Regulations, Rulings And Cases, Stefan F. Tucker Dec 1995

The Year In Review: A Discussion Of Significant Regulations, Rulings And Cases, Stefan F. Tucker

William & Mary Annual Tax Conference

No abstract provided.


Tax Court Decision Unsettles Irs Subchapter S Procedures, Glenn E. Coven Feb 1988

Tax Court Decision Unsettles Irs Subchapter S Procedures, Glenn E. Coven

Faculty Publications

No abstract provided.


Making Subchapter S Work, Glenn E. Coven Jul 1986

Making Subchapter S Work, Glenn E. Coven

Faculty Publications

No abstract provided.


Tax Policy Analysis Of Bob Jones University V. U.S, Charles O. Galvin, Neal Devins Jan 1983

Tax Policy Analysis Of Bob Jones University V. U.S, Charles O. Galvin, Neal Devins

Faculty Publications

No abstract provided.


Standing To Challenge Tax Treatment Of Competitors May 1978

Standing To Challenge Tax Treatment Of Competitors

William & Mary Law Review

No abstract provided.