Open Access. Powered by Scholars. Published by Universities.®
- Discipline
-
- Taxation-Federal (1795)
- Business Organizations Law (1228)
- Taxation-Transnational (914)
- Taxation-Federal Estate and Gift (854)
- Law and Economics (767)
-
- Taxation-State and Local (752)
- Estates and Trusts (700)
- Constitutional Law (649)
- International Law (579)
- Legislation (553)
- Banking and Finance Law (540)
- Administrative Law (521)
- State and Local Government Law (517)
- Property Law and Real Estate (484)
- International Trade Law (449)
- Commercial Law (436)
- Contracts (390)
- Law and Politics (377)
- Criminal Law (354)
- Social Welfare Law (349)
- Insurance Law (344)
- Family Law (342)
- Health Law and Policy (341)
- Law and Society (340)
- Bankruptcy Law (337)
- Internet Law (330)
- Organizations Law (325)
- Courts (314)
- Institution
-
- University of Michigan Law School (812)
- Selected Works (804)
- William & Mary Law School (606)
- Maurer School of Law: Indiana University (299)
- Maurice A. Deane School of Law at Hofstra University (269)
-
- Vanderbilt University Law School (242)
- SelectedWorks (241)
- The University of Akron (210)
- West Virginia University (189)
- University of Georgia School of Law (162)
- Boston University School of Law (144)
- Florida State University College of Law (139)
- Universitas Indonesia (131)
- University of Richmond (121)
- University of Kentucky (119)
- Washington and Lee University School of Law (111)
- Seattle University School of Law (109)
- Villanova University Charles Widger School of Law (106)
- Brooklyn Law School (105)
- UIC School of Law (101)
- San Jose State University (99)
- New York Law School (97)
- University of Florida Levin College of Law (90)
- The Peter A. Allard School of Law (89)
- Columbia Law School (86)
- Schulich School of Law, Dalhousie University (85)
- Georgetown University Law Center (84)
- University of Maryland Francis King Carey School of Law (83)
- University of Baltimore Law (81)
- Brigham Young University Law School (77)
- Keyword
-
- Taxation (965)
- Tax (526)
- Income tax (323)
- Tax law (301)
- IRS (284)
-
- Internal Revenue Code (277)
- Tax reform (166)
- Tax policy (161)
- Tax Law (154)
- Corporations (118)
- Internal Revenue Service (115)
- Partnerships (103)
- Taxes (101)
- Estate tax (94)
- International tax (92)
- Corporate tax (90)
- Taxation-Federal Income (82)
- Economics (77)
- OECD (69)
- Legislation (68)
- VAT (68)
- Constitutional Law (63)
- Property (61)
- Tax avoidance (61)
- Tax evasion (59)
- Income Tax (55)
- Law and Economics (54)
- Corporate Taxation (52)
- Constitutional law (51)
- Federal income tax (51)
- Publication Year
- Publication
-
- Michigan Law Review (474)
- Faculty Scholarship (438)
- William & Mary Annual Tax Conference (433)
- Articles (315)
- ACTEC Law Journal (267)
-
- West Virginia Law Review (186)
- Indiana Law Journal (180)
- Akron Tax Journal (160)
- Faculty Publications (159)
- All Faculty Scholarship (158)
- Vanderbilt Law Review (155)
- Scholarly Works (144)
- "Dharmasisya” Jurnal Program Magister Hukum FHUI (126)
- Scholarly Publications (117)
- Articles by Maurer Faculty (104)
- The Contemporary Tax Journal (99)
- Hugh J. Ault (93)
- Journal Articles (92)
- All Faculty Publications (89)
- Seattle University Law Review (87)
- UF Law Faculty Publications (87)
- Villanova Law Review (84)
- University of Richmond Law Review (81)
- Georgetown Law Faculty Publications and Other Works (80)
- UIC Law Review (77)
- Law & Economics Working Papers (72)
- William & Mary Law Review (68)
- Kentucky Law Journal (65)
- Vanderbilt Journal of Transnational Law (65)
- Washington and Lee Law Review (62)
- Publication Type
Articles 5341 - 5370 of 8086
Full-Text Articles in Tax Law
Enterprise Risk Management: Realizing Profit From Risk, Raymond M. Slabaugh
Enterprise Risk Management: Realizing Profit From Risk, Raymond M. Slabaugh
William & Mary Annual Tax Conference
No abstract provided.
Valuations In The Business Setting: International Glossary Of Business Valuation Terms
Valuations In The Business Setting: International Glossary Of Business Valuation Terms
William & Mary Annual Tax Conference
No abstract provided.
Valuations In The Business Setting: Exhibits
Valuations In The Business Setting: Exhibits
William & Mary Annual Tax Conference
No abstract provided.
The Evoloving Nature Of Tax Practice, Stefan F. Tucker
The Evoloving Nature Of Tax Practice, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
The Zen Of Corporate Capital Structure Neutrality, Herwig J. Schlunk
The Zen Of Corporate Capital Structure Neutrality, Herwig J. Schlunk
Michigan Law Review
It is well understood that corporate capital structure affects tax collections. Most basically, corporate interest expense is deductible. With each interest accrual, the corporate tax base shrinks. Thus, there is a broad range of circumstances in which corporate managers are encouraged by the Internal Revenue Code (the "Code") to load their corporate capital structures with debt. But there is little support for the proposition that Conpress desires corporations to adopt such debt-laden capital structures. Indeed, much tax legislation suggests congressional displeasure with the achievable degree of corporate self- integration. On the other hand, corporate equity has its charms: shareholders are …
The Death Of The Income Tax (Or, The Rise Of America’S Universal Wage Tax), Edward J. Mccaffery
The Death Of The Income Tax (Or, The Rise Of America’S Universal Wage Tax), Edward J. Mccaffery
Indiana Law Journal
The killing of the income tax has not been open and notorious: such is not the style of contemporary politics. As with other markers of progressive social policy—the promises of universal health care, Obamacare, come to mind6—the income tax is dying a death by stealth, albeit stealth played out in plain view. The plot lines of the tragedy are apparent. The individual “income” tax has been split in two. One tax, for the masses, is a simple, increasingly formless wage tax. This wage/income tax adds higher brackets onto the payroll tax, the model toward which the wage/income tax aims, to …
After Drye: The Likely Attachment Of The Federal Tax Lien To Tenancy-By-The- Entireties Interests, Steve R. Johnson
After Drye: The Likely Attachment Of The Federal Tax Lien To Tenancy-By-The- Entireties Interests, Steve R. Johnson
Indiana Law Journal
No abstract provided.
After Drye: The Likely Attachment Of The Federal Tax Lien To Tenancy-By-The-Entireties, Steve R. Johnson
After Drye: The Likely Attachment Of The Federal Tax Lien To Tenancy-By-The-Entireties, Steve R. Johnson
Scholarly Publications
On December 7, 1999, the United States Supreme Court unanimously decided Drye v. United States, a case likely to be a landmark in federal tax lien law. Drye clarified what had been muddied by previous Supreme Court and lower court decisions: the proper relation between state law and federal law in tax lien attachment cases. That clarification will permit-indeed, compel-greater analytical precision as future courts address tax lien cases. This Article discusses one such line of cases.
It has long been the rule that the federal tax lien does not attach to tenancy-by-the entireties interests when (1) only one of …
Better America Bonds: Better Is In The Eye Of The Beholder, Robert A. Fisher
Better America Bonds: Better Is In The Eye Of The Beholder, Robert A. Fisher
William & Mary Environmental Law and Policy Review
No abstract provided.
Only Congress Can Create Deductions, Deborah A. Geier
Only Congress Can Create Deductions, Deborah A. Geier
Law Faculty Articles and Essays
A series of recent and controversial cases has raised the issue of how plaintiffs must treat attorneys' fees and costs that are paid out of otherwise includable settlement or litigation awards. Everyone seems to agree that under tax policy and theory plaintiffs should not be saddled with this burden. Many have expressed the desire that Congress amend the Code to correct the problem. The more difficult question, which the author addresses, is whether courts can act to protect these plaintiffs in the absence of Congressional action.
Breaking The Glass Slipper: Reflections On The Self-Employment Tax, Patricia E. Dilley
Breaking The Glass Slipper: Reflections On The Self-Employment Tax, Patricia E. Dilley
UF Law Faculty Publications
Lawmakers and their staffs, in drafting tax legislation, often resemble Prince Charming looking for Cinderella with that glass slipper in hand -- rather than start from scratch and draft a completely new tax provision. It is frequently easier, faster, and more reassuring to taxpayers and tax practitioners to use an existing statute or approach and simply amend it slightly to make it fit the need of the new provision. However, problems can arise from this approach.
In the original Grimm Brothers' version of the Cinderella story, for example, the wicked stepsisters were each so anxious to be the chosen one …
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Transcript From The Symposium: 'Globalization And The Taxation Of Foreign Investment', Hugh Ault
Hugh J. Ault
No abstract provided.
Some Meandering Thoughts On Plaintiffs And Their Attorneys' Fees And Costs, Deborah A. Geier
Some Meandering Thoughts On Plaintiffs And Their Attorneys' Fees And Costs, Deborah A. Geier
Law Faculty Articles and Essays
This article examines statutory interpretation in general and the common-law doctrines at issue in particular (the assignment-of-income doctrine as well as the doctrine first identified in the seminal case of Old Colony Trust). While the author believes that these plaintiffs ought--as a matter of policy and income tax theory--to escape taxation on the amounts paid to their attorneys, she belives that the issue is truly a " deduction" issue, not a "gross income" issue. The article concludes, however, that the ill-fitting application of "gross income" doctrine in this context leads to indefensible distinctions that sound superficially plausible under the rubric …
A Residual Damages Right Against The Irs: A Cure Worse Than The Disease, Steve R. Johnson
A Residual Damages Right Against The Irs: A Cure Worse Than The Disease, Steve R. Johnson
Scholarly Publications
Tax scholarship commonly has emphasized the substantive rules of tax liability, according less than due attention to tax procedure. Recently, however, this imbalance has been partly redressed as a result of the taxpayer rights movement. The major legislative products of the movement have been the Taxpayer Bill of Rights (TBORl) in 1988, the Taxpayer Bill of Rights 2 (TBOR2) in 1996,and the Taxpayer Bill of Rights (TBOR3) in 1998. Congress currently is considering a fourth installment in the series. These measures – especially TBOR3 – have provoked considerable useful commentary from both practitioners and academics.
Nonetheless, much work remains to …
No Hope (Credits) For Louisiana Coffers, Glenn E. Coven, Michael B. Lang
No Hope (Credits) For Louisiana Coffers, Glenn E. Coven, Michael B. Lang
Faculty Publications
No abstract provided.
Tax Liens, Tax Sales, And Due Process, Frank S. Alexander
Tax Liens, Tax Sales, And Due Process, Frank S. Alexander
Indiana Law Journal
No abstract provided.
Deconstructing The Debate Over State Taxation Of Electronic Commerce, Walter Hellerstein
Deconstructing The Debate Over State Taxation Of Electronic Commerce, Walter Hellerstein
Scholarly Works
Elsewhere on these pages, the distinguished economist Charles McLure begins his contribution to the debate over taxation of electronic commerce by observing that “America is focusing on the wrong issues in debating the taxation of electronic commerce ....” He proceeds to provide a fundamental critique of the states' existing sales tax regimes and he lays out a roadmap for radical reform of the system that would, in the course of curing the basic defects in the existing state sales tax structure, incidentally resolve many of the issues that currently dominate the debate over taxing electronic commerce. I do not disagree …
Policy Issues Relating To The U.S. Taxation Of Foreign Persons Engaged In Business In The United States Through Agents: Some Proposals For Reform, Richard Crawford Pugh
Policy Issues Relating To The U.S. Taxation Of Foreign Persons Engaged In Business In The United States Through Agents: Some Proposals For Reform, Richard Crawford Pugh
San Diego International Law Journal
This Article will begin by discussing the circumstances under which a foreign person will be deemed to be engaged in a trade or business in the United States and by examining a proposal that would introduce a great level of certainty for tax planners and the IRS. The principal focus of the Article, however, will be on the circumstances under which the United States should impose U.S. income tax on the income of a foreign person from a business conducted, not directly in the United States, but through an agent acting on behalf of the foreign person. The treatment of …
A Framework On Consumption Taxes And Their Impact On International Trade, Jane L. Seigendall
A Framework On Consumption Taxes And Their Impact On International Trade, Jane L. Seigendall
Penn State International Law Review
No abstract provided.
The Tyranny Of Money, Edward J. Mccaffery
The Tyranny Of Money, Edward J. Mccaffery
Michigan Law Review
The more things change, the more they stay the same. A human activity almost as venerable as the accumulation and opulent display of vast riches is the condemnation of the accumulation and opulent display of vast riches. People have been busily engaged at each for several millennia now. Both continue in full flower as America races into the twenty-first century with its liberal capitalist democracy ascendant around the world, its rich richer than ever, its less-rich curiously lagging behind. Yet figuring out what, exactly, is wrong with the excessive accumulation and opulent display of wealth, on the one hand, and …
Some Thoughts On The Incidence Of Foreign Taxes, Deborah A. Geier
Some Thoughts On The Incidence Of Foreign Taxes, Deborah A. Geier
Law Faculty Articles and Essays
This 2000 article was prompted by the fact pattern and Tax Court decision in Compaq Computer v. Commissioner, 113 T.C. 363 (1999). While other commentary has focused on the application of the "economic substance" doctrine in this case, this article focuses instead on the ability to take foreign tax credits based not on economic incidence but on legal incidence and how this allows for crediting of foreign taxes economically borne by other actors in the marketplace.
A Wrong Step In The Right Direction: The National Taxpayer Advocate And The 1998 Irs Restructuring And Reform Act, Heather B. Conoboy
A Wrong Step In The Right Direction: The National Taxpayer Advocate And The 1998 Irs Restructuring And Reform Act, Heather B. Conoboy
William & Mary Law Review
No abstract provided.
Choice Of Small Business Tax Entity, John W. Lee
Choice Of Small Business Tax Entity, John W. Lee
Faculty Publications
This article summarizes parts of Lee’s forthcoming article “A Populist Political Perspective of the Business Tax Entities Universe: Hey the Stars Might Lie But the Numbers Never Do,” 78 Texas L. Rev. 885 (2000). Conventional wisdom, says Lee, holds that the LLC, due to its limited liability and hassle-free single level of taxation, will supplant C and S corporations as the choice of entity for new businesses. In fact, in most jurisdictions corporate formations outnumber LLC formations 2:1 or more, and IRS Statistics of Income (SOI) projects that the S corporation will be the fastest growing tax entity for 2000 …
The Cash Balance Controversy, Edward A. Zelinsky
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
All Faculty Scholarship
This piece, included in the University of Hawaii Law Review's symposium issue on the Bishop Estate, explores the relationship between the new intermediate sanctions law and the IRS's power to revoke tax exemption under § 501(c)(3). Inspired by the storied setting, I indulge in a fantasy: This article pretends that the IRS revoked the Estate's exemption, and takes the form of the Tax Court declaratory judgment opinion. I reluctantly 'rule' that exemption was not appropriate, because State enforcement action against the trustees was proceeding. (However, this forum allows me to hedge my argument by producing two concurring and one dissenting …
My First Grade Teacher, Jeffrey G. Sherman
My First Grade Teacher, Jeffrey G. Sherman
All Faculty Scholarship
No abstract provided.
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody
Evelyn Brody
This piece, included in the University of Hawaii Law Review's symposium issue on the Bishop Estate, explores the relationship between the new intermediate sanctions law and the IRS's power to revoke tax exemption under § 501(c)(3). Inspired by the storied setting, I indulge in a fantasy: This article pretends that the IRS revoked the Estate's exemption, and takes the form of the Tax Court declaratory judgment opinion. I reluctantly 'rule' that exemption was not appropriate, because State enforcement action against the trustees was proceeding. (However, this forum allows me to hedge my argument by producing two concurring and one dissenting …
Electronic Commerce And The State And Federal Tax Bases, J. Clifton Fleming Jr.
Electronic Commerce And The State And Federal Tax Bases, J. Clifton Fleming Jr.
BYU Law Review
The federal income tax does not apply to profits generated by pure mail order sales originating from outside the United States, and state and local consumption taxes are effectively inapplicable to pure mail order sales originating from outside the taxing jurisdiction. These conclusions seem fully applicable to federal taxation of income from sales that are initially solicited through Internet advertising and then transacted over the Internet between a customer in the United States and an out-of-country seller's out-of-country website. Similar conclusions are also, arguably, applicable in the case of state and local consumption taxes. Extension of the mail order tax …
Leveling The Playing Field: A Business Perspective On Taxing E-Commerce, Val John Christensen
Leveling The Playing Field: A Business Perspective On Taxing E-Commerce, Val John Christensen
BYU Law Review
No abstract provided.
One Country, Two (Taxation) Sytems: A Treaty In All But Name, Andrew Halkyard
One Country, Two (Taxation) Sytems: A Treaty In All But Name, Andrew Halkyard
Washington International Law Journal
It came as no small surprise when it was announced in February 1998 that the Chinese mainland ("the Mainland") and Hong Kong had agreed to enter into an arrangement for the avoidance of double taxation of income. Although concerns of double taxation between the Mainland and Hong Kong tended to be more academic than practical, this arrangement helps establish a firm foundation for future co-operation by the Mainland and Hong Kong on trade and other economic matters. From a Hong Kong taxation perspective, it is one of the most significant developments to have occurred for a very long time. From …