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Articles 1 - 30 of 40
Full-Text Articles in Tax Law
Standing On The Shoulders Of Llcs: Tax Entity Status And Decentralized Autonomous Organizations, Samuel D. Brunson
Standing On The Shoulders Of Llcs: Tax Entity Status And Decentralized Autonomous Organizations, Samuel D. Brunson
Georgia Law Review
Since the formation of the first decentralized autonomous organization in 2016, their use has exploded. Thousands of DAOs now try to take advantage of smart contracts to solve a problem that plagues business entities: the gulf between ownership and management. Armed with smart contracts and requiring token-holders to vote on any change in strategy, DAOs dispense with the management layer so necessary in traditional business entities.
DAOs owe their existence to technology. Without blockchain, without cryptocurrency, and without smart contracts, there would be no DAOs. But they owe their explosive to something much more unexpected: Treasury regulations.
In the wake …
Stay Schemin’: Tax Court’S Recent Ruling On Credit Card Rewards And The Impact This Ruling Has On Future Rewards Programs, Hunter Davis
Stay Schemin’: Tax Court’S Recent Ruling On Credit Card Rewards And The Impact This Ruling Has On Future Rewards Programs, Hunter Davis
Georgia Law Review
Beyond the utility of actual “credit,” the most important perk cardholders seek to capitalize on are the rewards that each cardholder’s particular credit card offers. Cardholders look for the most bang for their buck in terms of rewards and points. Ranging from frequent flyer miles to cash back to everything in between, rewards programs have expanded and diversified rapidly over the past several decades, and consumers cannot get enough. So much so that the question of whether, and when, consumer loyalty rewards should be taxable has arisen and persists today. The Internal Revenue Service (IRS) and the Tax Court have …
Pay Toll With Coins: Looking Back On Fbar Penalties And Prosecutions To Inform The Future Of Cryptocurrency Taxation, Caroline T. Parnass
Pay Toll With Coins: Looking Back On Fbar Penalties And Prosecutions To Inform The Future Of Cryptocurrency Taxation, Caroline T. Parnass
Georgia Law Review
Cryptocurrencies are gaining a foothold in the global
economy, and the government wants its cut. However, few
people are reporting cryptocurrency transactions on their tax
returns. How will the IRS solve its cryptocurrency
noncompliance problem? Its response so far bears many
similarities to the government’s campaign to increase Reports
of Foreign Bank and Financial Accounts (FBARs). FBAR
noncompliance penalties are notoriously harsh, and the
government has pursued them vigorously. This Note explores
the connections and differences between cryptocurrency
reporting and foreign bank account reporting in an effort to
predict the future regime of cryptocurrency tax compliance.
Sinking The Island Of Constitutional Tax Immunity: A Uniform Approach To State Taxes On Goods In Transit Under The Import-Export Clause, Warren F. Smith
Sinking The Island Of Constitutional Tax Immunity: A Uniform Approach To State Taxes On Goods In Transit Under The Import-Export Clause, Warren F. Smith
Georgia Law Review
The Framers of the U.S. Constitution adopted the
Import-Export Clause to prohibit the states from
interfering in international relations, to preserve import
revenue for the federal government, and to ensure
harmony between the states. The purposive inquiry
established by Michelin and Washington Stevedoring is
applied for all imports and exports except one category:
export goods in transit. The pre-Michelin decision,
Richfield Oil, provides complete constitutional tax
immunity for export goods in transit. This island of
constitutional tax immunity forces local taxpayers to
subsidize exporters and foreign consumers and unfairly
burdens coastal states with the regulatory,
administrative, and environmental costs of …
Guidance Is Definitive, Reality Is Frequently Inaccurate: The Lingering Saga Of Rev. Rul. 91-32, Robert L. Daily
Guidance Is Definitive, Reality Is Frequently Inaccurate: The Lingering Saga Of Rev. Rul. 91-32, Robert L. Daily
Georgia Law Review
Partnership and international taxation are two of the
most mind-numbing and inconsistent areas of the law.
Even more confusion occurs when the two intersect, such
as when a nonresident sells an interest in a U.S.
partnership. Many have wasted precious time and
abundant ink to come up with a solution. The IRS first
tried in Rev. Rul. 91-32, concluding that a nonresident
would be subject to tax if the partnership had assets
producing income generated from property in United
States. Although the guidance was appropriately
criticized for being statutorily inconsistent, this Note
argues that it nonetheless got to the right …
America’S (D)Evolving Childcare Tax Laws, Shannon W. Mccormack
America’S (D)Evolving Childcare Tax Laws, Shannon W. Mccormack
Georgia Law Review
Proponents touted the Tax Cuts and Jobs Act (the
TCJA)—enacted in the twilight of 2017—by claiming it
would help American working families. But while the
TCJA expanded some benefits available to parents with
dependent children, these parental tax benefits may be
claimed regardless of whether or to what extent
childcare costs are incurred to work outside the home.
To help working parents with these (often significant)
costs, Congress might have turned to two other
mechanisms in the tax law—the “child and dependent
care credit” and the “dependent care exclusion.” While
these childcare tax benefits are only available to working
parents …
Taxation – Selection Of Exchange Rate For Translation Purposes -- Where Multiple Exchange Rates Exist For A Foreign Currency And The Underlying Transaction Is Financial In Nature, The Proper Rate For Translation Components Of Taxable Income Is The "Free" Market Rate (Durovic V. Commissioner Of Internal Revenue, 7th Cir. 1976), Tim J. Floyd
Georgia Journal of International & Comparative Law
No abstract provided.
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.)., Donald O. Clark
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.)., Donald O. Clark
Georgia Journal of International & Comparative Law
No abstract provided.
The Internet Tax Freedom Act: Necessary Protection Or Deferral Of The Problem?, Timothy Fallaw
The Internet Tax Freedom Act: Necessary Protection Or Deferral Of The Problem?, Timothy Fallaw
Journal of Intellectual Property Law
No abstract provided.
Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd
Georgia Journal of International & Comparative Law
No abstract provided.
Branding Taxation, Xuan-Thao Nguyen, Jeffrey A. Maine
Branding Taxation, Xuan-Thao Nguyen, Jeffrey A. Maine
Georgia Law Review
Branding is important not only to businesses, but also to the economy. The intellectual property laws and tax laws should thus further the legitimate goals of encouraging and protecting brand investments while maintaining a sound tax base. Intellectual property protections for branding depend on advertisement and enforcement, both of which demand significant amounts of private investment by firms. Although one would expect similar tax treatments of both categories of investment, the categories are actually treated as vastly different for federal income tax purposes. Under the current tax system, advertising costs incurred to foster brand equality are generally expensed whereas litigation …
Saving The Next Superman: An Alternative Approach To The Taxation Of Copyright Termination Rights, Benjamin Newell
Saving The Next Superman: An Alternative Approach To The Taxation Of Copyright Termination Rights, Benjamin Newell
Journal of Intellectual Property Law
No abstract provided.
Trade Act Of 1974-Countervailing Duties-Nonexcessive Remission Of Foreign Excise Tax On Products Imported Into The United States Does Not Constitute A Bounty Or Grant Requiring The Levy Of Countervailing Duties, Garry Seltzer
Georgia Journal of International & Comparative Law
No abstract provided.
The Impact Of The United States Tax Laws On International Technology Transfer: An Overview And Some Suggestion For Minimizing The Bite, Marcus B. Finnegan, Robert E. Mccarthy
The Impact Of The United States Tax Laws On International Technology Transfer: An Overview And Some Suggestion For Minimizing The Bite, Marcus B. Finnegan, Robert E. Mccarthy
Georgia Journal of International & Comparative Law
No abstract provided.
Constitutional Law, Import-Export Clause: Non-Discriminatory, Fairly Apportioned Excise Tax Applied To Stevedoring Companies Loading And Unloading Goods In Imports And Export Transit Does Not Constitute An Import Or Duty Within The Prohibition Of The Import-Export Clause, Tony G. Mills
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Georgia Journal of International & Comparative Law
No abstract provided.
Through The Antiboycott Morass To An Export Priority, Mark D. Menefee, Don Samuel
Through The Antiboycott Morass To An Export Priority, Mark D. Menefee, Don Samuel
Georgia Journal of International & Comparative Law
No abstract provided.
A Practitioner's Guide To United States Employment Taxation Of Nonresident Aliens Working In The United States, John L. Gornall Jr., John B. Copenhaver
A Practitioner's Guide To United States Employment Taxation Of Nonresident Aliens Working In The United States, John L. Gornall Jr., John B. Copenhaver
Georgia Journal of International & Comparative Law
No abstract provided.
The Development Of Foreign Investment Law In Egypt And Its Effect On Private Foreign Investment, George E. Bushnell Iii
The Development Of Foreign Investment Law In Egypt And Its Effect On Private Foreign Investment, George E. Bushnell Iii
Georgia Journal of International & Comparative Law
No abstract provided.
Foreign Investment In The People's Republic Of China: Compensation Trade, Joint Ventures, Industrial Property Protection And Dispute Settlement, Kevin K. Maher
Foreign Investment In The People's Republic Of China: Compensation Trade, Joint Ventures, Industrial Property Protection And Dispute Settlement, Kevin K. Maher
Georgia Journal of International & Comparative Law
No abstract provided.
People's Republic Of China - Personal Income Tax, Olive E. Bell
People's Republic Of China - Personal Income Tax, Olive E. Bell
Georgia Journal of International & Comparative Law
No abstract provided.
International Tax Free Exchanges: The Structure Of I.R.C. Section 367, Vikram A. Gosain
International Tax Free Exchanges: The Structure Of I.R.C. Section 367, Vikram A. Gosain
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii
Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii
Georgia Journal of International & Comparative Law
No abstract provided.
The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty, Robert R. Oliva
The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty, Robert R. Oliva
Georgia Journal of International & Comparative Law
No abstract provided.
Multistate Export Trade Promotion Under The Export Trading Company Act Of 1982, Joseph M. Gannam
Multistate Export Trade Promotion Under The Export Trading Company Act Of 1982, Joseph M. Gannam
Georgia Journal of International & Comparative Law
No abstract provided.
Annual Survey Of Developments In International Trade Law: 1983, Georgia Journal Of International And Comparative Law
Annual Survey Of Developments In International Trade Law: 1983, Georgia Journal Of International And Comparative Law
Georgia Journal of International & Comparative Law
No abstract provided.
Annual Survey Of Developments In International Trade Law: 1984, Georgia Journal Of International And Comparative Law
Annual Survey Of Developments In International Trade Law: 1984, Georgia Journal Of International And Comparative Law
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Reform Act Of 1984 - International Related-Party Factoring - A Major Tax Loophole For Multinational Corporations Is Closed, Phil Conner
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors, Lee C. Dilworth
Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors, Lee C. Dilworth
Georgia Journal of International & Comparative Law
No abstract provided.
New Tax Withholding Rules For Foreign-Owned United States Real Estate, John D. Maiers
New Tax Withholding Rules For Foreign-Owned United States Real Estate, John D. Maiers
Georgia Journal of International & Comparative Law
No abstract provided.