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Tax Law Commons

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1986

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Institution
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Articles 1 - 30 of 70

Full-Text Articles in Tax Law

The Tax Reform Act Of 1986: Simplicity, Equity, And Efficiency, Douglas Holtz-Eakin Dec 1986

The Tax Reform Act Of 1986: Simplicity, Equity, And Efficiency, Douglas Holtz-Eakin

Akron Tax Journal

The Tax Reform Act of 1986 (TRA86) has added another chapter to the already crowded tax history of the 1980's. Since the election of Ronald Reagan in 1980, the nation has seen several major tax changes: The Economic Recovery Tax Act in 1981, The Tax Equity and Fiscal Responsibility Act in 1982, and TRA86. With tax reform now well down on the list of legislative priorities (at least until next year!) it seems a propitious time for a general assessment of the structure of the federal tax system.

This paper reviews TRA86 with an eye toward these issues. The order …


Tax Shelter Limitations, Thomas R. Frantz Dec 1986

Tax Shelter Limitations, Thomas R. Frantz

William & Mary Annual Tax Conference

No abstract provided.


Tax Exempt Bond Provisions, Hugh L. Patterson, Guy R. Friddell, William W. Harrison Dec 1986

Tax Exempt Bond Provisions, Hugh L. Patterson, Guy R. Friddell, William W. Harrison

William & Mary Annual Tax Conference

No abstract provided.


Capital Cost Recovery Changes, B. Cary Tolley Iii Dec 1986

Capital Cost Recovery Changes, B. Cary Tolley Iii

William & Mary Annual Tax Conference

No abstract provided.


The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom Dec 1986

The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom

William & Mary Annual Tax Conference

No abstract provided.


A Review Of The Provisions Of The Tax Reform Act Of 1986 Relating To Corporate Acquisitions, Samuel C. Thompson Jr. Dec 1986

A Review Of The Provisions Of The Tax Reform Act Of 1986 Relating To Corporate Acquisitions, Samuel C. Thompson Jr.

William & Mary Annual Tax Conference

No abstract provided.


Employee Benefits Legislation- Another Round: The Tough Get Tougher, Mark S. Dray Dec 1986

Employee Benefits Legislation- Another Round: The Tough Get Tougher, Mark S. Dray

William & Mary Annual Tax Conference

No abstract provided.


Current Issues And Developments Involving Sales Or Exchanges Of Real Estate: The Impact Of Tax Reform 1986 On Real Estate Investments And Activities, Robert G. Gottlieb Dec 1986

Current Issues And Developments Involving Sales Or Exchanges Of Real Estate: The Impact Of Tax Reform 1986 On Real Estate Investments And Activities, Robert G. Gottlieb

William & Mary Annual Tax Conference

No abstract provided.


Purchase Price Allocations In Cost Basis Acquisitions: Sections 338 And 1060 Under The 1986 Code, William Rogers, John W. Lee Dec 1986

Purchase Price Allocations In Cost Basis Acquisitions: Sections 338 And 1060 Under The 1986 Code, William Rogers, John W. Lee

William & Mary Annual Tax Conference

No abstract provided.


Corporate Tax Changes In The 1986 Tax Reform Act, Richard E. May Dec 1986

Corporate Tax Changes In The 1986 Tax Reform Act, Richard E. May

William & Mary Annual Tax Conference

No abstract provided.


South Dakota Airplane Tax Hangs By A Technical Thread, Jeffrey S. Lehman Oct 1986

South Dakota Airplane Tax Hangs By A Technical Thread, Jeffrey S. Lehman

Cornell Law Faculty Publications

No abstract provided.


Wimberly V. Labor & Industrial Relations Commission Of Missouri, Lewis F. Powell Jr. Oct 1986

Wimberly V. Labor & Industrial Relations Commission Of Missouri, Lewis F. Powell Jr.

Supreme Court Case Files

No abstract provided.


Contribution By Feeder Corporation To Parent Foundation: Crosby Valve Revisited Sep 1986

Contribution By Feeder Corporation To Parent Foundation: Crosby Valve Revisited

Washington and Lee Law Review

No abstract provided.


Making Subchapter S Work, Glenn E. Coven Jul 1986

Making Subchapter S Work, Glenn E. Coven

Faculty Publications

No abstract provided.


Start-Up Costs, Section 195 And Clear Reflection Of Income: A Tale Of Talismans, Tacked-On Tax Reform And A Touch Of Basics, John W. Lee Jul 1986

Start-Up Costs, Section 195 And Clear Reflection Of Income: A Tale Of Talismans, Tacked-On Tax Reform And A Touch Of Basics, John W. Lee

Faculty Publications

No abstract provided.


No Pain—No Gain—Should Personal Injury Damages Keep Their Tax Exempt Status, Douglas K. Chapman Jul 1986

No Pain—No Gain—Should Personal Injury Damages Keep Their Tax Exempt Status, Douglas K. Chapman

University of Arkansas at Little Rock Law Review

No abstract provided.


Qualified Domestic Relations Orders, Craig Westbrook Jul 1986

Qualified Domestic Relations Orders, Craig Westbrook

University of Arkansas at Little Rock Law Review

No abstract provided.


State And Local Taxation Of Financial Institutions:An Opportunity For Reform, C. James Judson, Susan G. Duffy May 1986

State And Local Taxation Of Financial Institutions:An Opportunity For Reform, C. James Judson, Susan G. Duffy

Vanderbilt Law Review

Forces at work in both public and private sectors may soon change the way state and local political subdivisions tax financial institutions. The market for financial services is changing dramatically. Governments have expanded substantially the scope of activities in which financial depositories may engage. The competitive environment for financial activities also is changing as general business corporations enter the financial services field, an area previously considered the exclusive domain of financial institutions. Financial institutions have increasing opportunities for interstate activity, which offers both risks and challenges. These changes have occurred during a period in which the extensive framework of state …


Discriminatory Demands And Divided Decisions: State And Local Taxation Of Rail, Motor,And Air Carrier Property, Scott M. Schoenwald May 1986

Discriminatory Demands And Divided Decisions: State And Local Taxation Of Rail, Motor,And Air Carrier Property, Scott M. Schoenwald

Vanderbilt Law Review

To prevent the unreasonable burdening of interstate commerce that results from discriminatory state and local taxation of rail, motor, and air carrier property, Congress enacted section 306 of the Railroad Revitalization and Regulatory Reform Act of 1976 (4R Act), 1 section 31 of the Motor Carrier Act of 1980, and section 532(b) of the Airport and Airway Improvement Act of 1982.' These statutes represent the result of two decades of congressional deliberation over property tax discrimination against interstate carriers. Because Congress enacted the 4R Act first and because tax discrimination against rail carriers has been the most egregious,the overwhelming majority …


Significant Sales And Use Tax Developments During The Past Half Century, Jerome R. Hellerstein May 1986

Significant Sales And Use Tax Developments During The Past Half Century, Jerome R. Hellerstein

Vanderbilt Law Review

Sales and use taxes have been the great growth taxes of state and local governments during the past half century. The general sales tax, along with selected levies on gasoline, tobacco, and liquor, has had phenomenal growth during the past fifty years. In 1932 only Mississippi imposed a general sales tax. It produced seven million dollars, less than one percent of Mississippi's total tax revenues. Taxes once introduced, however, tend to grow at least until widespread dissatisfaction leads to a taxpayers' revolt,such as California's Proposition 13' or the election of President Ronald Reagan and the ascendancy of political conservatism and …


Collection Of The Use Tax On Out-Of-State Mail-Order Sales, Paul J. Hartman May 1986

Collection Of The Use Tax On Out-Of-State Mail-Order Sales, Paul J. Hartman

Vanderbilt Law Review

The states' inability to collect taxes on out-of-state mail-order sales constitutes a major fiscal problem. The federal government's Advisory Commission on Intergovernmental Relations estimates that states are losing as much as 1.5 billion dollars each year in unpaid out-of-state mail-order purchase taxes.'

In addition to raising revenue, the compensating use tax serves two purposes: (1) The use tax helps local sellers to compete with retail dealers in other states who are subject to a lesser tax burden;and (2) the use tax avoids the likelihood of draining the taxing state's revenue by removing buyers' incentive or temptation to go bargain hunting …


Selected Issues In State Business Taxation, Walter Hellerstein May 1986

Selected Issues In State Business Taxation, Walter Hellerstein

Scholarly Works

This Article surveys selected issues in state business taxation. The topics were chosen with the hope that they would be of general interest to the conference for which this Article originally was prepared. The Article therefore eschews the detailed case analysis that typifies much of the law review writing about state and local taxation--including my own--and focuses instead on broader policy and economic questions that those concerned with state business taxation should find no less important. Part II of this Article considers business taxes and state tax incentives. Part III discusses federal and state tax conformity. Part IV addresses a …


The Personal Income Tax As A Component Of State Tax Structure, William F. Fox May 1986

The Personal Income Tax As A Component Of State Tax Structure, William F. Fox

Vanderbilt Law Review

This Article evaluates the pros and cons of a state individual income tax from the perspective of an economist. The Article examines the income tax as one component of a tax structure that is best suited for raising a given level of revenues. The important assumption in the analysis is that the level of state public expenditures is determined by residents' demand for public services. This assumption does not preclude the tax structure from allowing greater or lesser expenditures than are demanded during any single year; rather, the assumption is that over time tax levels provide revenues that are in …


The Computer's Role In Simplifying Compliance With State And Local Taxation, Ray Westphal May 1986

The Computer's Role In Simplifying Compliance With State And Local Taxation, Ray Westphal

Vanderbilt Law Review

I recently polled several tax managers of large corporations that engage in a multi-state business and asked them whether their companies could stay in reasonable compliance with state and local tax law without using the computer. All said that it would be impossible to meet the compliance requirements of the states and localities without heavy dependence on computers. This reliance on the computer is not surprising given the amount of data that firms must reference to keep up with the thousands of taxing jurisdictions throughout the United States. The many different types of taxes that governmental bodies impose further complicate …


Attending To Legal Tender: The Perils Of Structuring Currency Transactions To Avoid Treasury's Reporting Requirements, Leonard R. Rosenblatt, Lawrence S. Feld Apr 1986

Attending To Legal Tender: The Perils Of Structuring Currency Transactions To Avoid Treasury's Reporting Requirements, Leonard R. Rosenblatt, Lawrence S. Feld

Articles & Chapters

No abstract provided.


Distinguishing Between Capital Expenditures And Ordinary Business Expenses: A Proposal For A Universal Standard, Steven J. Greene Apr 1986

Distinguishing Between Capital Expenditures And Ordinary Business Expenses: A Proposal For A Universal Standard, Steven J. Greene

University of Michigan Journal of Law Reform

It is apparent from an examination of the various court decisions that there is no single, common standard used to distinguish between capital expenditures and ordinary business expenses. The courts are not completely to blame for this situation, however, because the Internal Revenue Code provides little guidance on the capital/ordinary distinction. This Note proposes an amendment to the Tax Code that would provide courts with a universal standard to apply in differentiating between the two types of expenditures and that best reflects the general purpose of the Code in matching income with its related expenses. Part I analyzes the historical …


Tefra And The Origination Clause: Taking The Oath Seriously, Thomas L. Jipping Apr 1986

Tefra And The Origination Clause: Taking The Oath Seriously, Thomas L. Jipping

Buffalo Law Review

No abstract provided.


Legal Perspectives On The Interstate Incidence And Shifting Of State And Local Taxes, Walter Hellerstein Apr 1986

Legal Perspectives On The Interstate Incidence And Shifting Of State And Local Taxes, Walter Hellerstein

Scholarly Works

Lawyers, especially constitutional lawyers, have long been concerned with the problems associated with the interstate incidence and shifting of state and local taxes. The Constitution has frequently been invoked as a restraint on the states' power to levy taxes on persons, property, or activities outside their borders. Yet the lawyer's view of tax incidence embodied in these constitutional disputes often bears little resemblance to the economist's. In recent years, however, lawyers have sought to import economic concepts of shifting and incidence into the legal analysis of the constitutional limitations on the states' power to export tax burdens to residents of …


X. Tax Mar 1986

X. Tax

Washington and Lee Law Review

No abstract provided.


Foreign Tax Provisions Of H.R. 3838, Hugh Ault, Stanford Ross, Gerard Brannon Feb 1986

Foreign Tax Provisions Of H.R. 3838, Hugh Ault, Stanford Ross, Gerard Brannon

Hugh J. Ault

No abstract provided.