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Articles 1 - 30 of 1920

Full-Text Articles in Taxation-Federal

The Negative Capital Account Maze, Walter D. Schwidetzky Aug 2017

The Negative Capital Account Maze, Walter D. Schwidetzky

All Faculty Scholarship

Outside Hubert I and Hubert II, there has been little discussion of negative capital accounts in the tax context and almost no discussion in the nontax context. Nontax law, however, is critically important. This report provides an integrated discussion of the application of tax and nontax law to negative capital accounts.

One of the challenges in writing this report is that it requires a discussion of both the at-risk rules of section 465 and the debt allocation rules of section 752. Complex issues involving sections 465 and 752 and their interaction are worthy of their own articles. Indeed, others have ...


The Present Status Of Multiple Taxation Of Intangible Property, Robert C. Brown Jun 2017

The Present Status Of Multiple Taxation Of Intangible Property, Robert C. Brown

Robert C. Brown

No abstract provided.


The Nature Of Income Tax, Robert C. Brown Jun 2017

The Nature Of Income Tax, Robert C. Brown

Robert C. Brown

No abstract provided.


The Theory And Practice Of Modern Taxation, By William R. Green, Robert C. Brown Jun 2017

The Theory And Practice Of Modern Taxation, By William R. Green, Robert C. Brown

Robert C. Brown

No abstract provided.


The Taxation Of Real Estate Subject To Mortgage And Other Incumbrances, Robert C. Brown Jun 2017

The Taxation Of Real Estate Subject To Mortgage And Other Incumbrances, Robert C. Brown

Robert C. Brown

The purpose of this paper is to examine the method of taxing real estate which is affected by incumbrances-either physical or legal. In particular, it is desired to consider the situation where the incumbrance is a mortgage or otherwise purely for security. And particular consideration is to be given to the propriety of taxing as real estate the interest of a non-resident mortgagee or similar incumbrancer in land within the jurisdiction.


The Time For Taking Deductions For Losses And Bad Debts For Income Tax Purposes, Robert C. Brown Jun 2017

The Time For Taking Deductions For Losses And Bad Debts For Income Tax Purposes, Robert C. Brown

Robert C. Brown

No abstract provided.


The Treatment For Federal Income Tax Purposes Of Errors In The Deduction Of Other Taxes, Robert C. Brown Jun 2017

The Treatment For Federal Income Tax Purposes Of Errors In The Deduction Of Other Taxes, Robert C. Brown

Robert C. Brown

No abstract provided.


State Taxation Of Interstate Commerce, And Federal And State Taxation In Intergovernmental Relations -- 1930-1932, Robert C. Brown Jun 2017

State Taxation Of Interstate Commerce, And Federal And State Taxation In Intergovernmental Relations -- 1930-1932, Robert C. Brown

Robert C. Brown

No abstract provided.


Regulations, Reenactment, And The Revenue Acts, Robert C. Brown Jun 2017

Regulations, Reenactment, And The Revenue Acts, Robert C. Brown

Robert C. Brown

No abstract provided.


State Taxation Of Interstate Commerce, And Federal And State Taxation In Intergovernmental Relations -- 1932-1935, Robert C. Brown Jun 2017

State Taxation Of Interstate Commerce, And Federal And State Taxation In Intergovernmental Relations -- 1932-1935, Robert C. Brown

Robert C. Brown

No abstract provided.


Reduction Of Tax Exemptions By Reason Of Receipt Of Tax-Exempt Income, Robert C. Brown Jun 2017

Reduction Of Tax Exemptions By Reason Of Receipt Of Tax-Exempt Income, Robert C. Brown

Robert C. Brown

No abstract provided.


Restrictions On State Taxation Because Of Interference With Federal Functions, Robert C. Brown Jun 2017

Restrictions On State Taxation Because Of Interference With Federal Functions, Robert C. Brown

Robert C. Brown

No abstract provided.


Intergovernmental Tax Immunity: Do We Need A Constitutional Amendment?, Robert C. Brown Jun 2017

Intergovernmental Tax Immunity: Do We Need A Constitutional Amendment?, Robert C. Brown

Robert C. Brown

No abstract provided.


Constitutional Limitations On Progressive Taxation Of Gross Income, Robert C. Brown Jun 2017

Constitutional Limitations On Progressive Taxation Of Gross Income, Robert C. Brown

Robert C. Brown

No abstract provided.


Book Review. Federal Taxation For The Lawyer By Houstin Shockey, Robert C. Brown Jun 2017

Book Review. Federal Taxation For The Lawyer By Houstin Shockey, Robert C. Brown

Robert C. Brown

No abstract provided.


Book Review. Selected Studies In Federal Taxation, 2nd Ed. By Randolph E. Paul, Robert C. Brown Jun 2017

Book Review. Selected Studies In Federal Taxation, 2nd Ed. By Randolph E. Paul, Robert C. Brown

Robert C. Brown

No abstract provided.


Book Review. Federal Estate And Gift Taxation By Randolph E. Paul, Robert C. Brown Jun 2017

Book Review. Federal Estate And Gift Taxation By Randolph E. Paul, Robert C. Brown

Robert C. Brown

No abstract provided.


Business Taxes Reinvented: The Dual Business Enterprise Income Tax, Edward D. Kleinbard Jun 2017

Business Taxes Reinvented: The Dual Business Enterprise Income Tax, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

This short overview and accompanying term sheet summarize the key features of a proposed comprehensive business tax environment termed the Dual Business Enterprise Income Tax (the Dual BEIT). The term sheet format is a useful mode of presentation for capturing in one accessible document the major policy recommendations of the Dual BEIT (or any other comprehensive tax reform proposal).

This paper makes the case that the Dual BEIT satisfies the objectives of policymakers from both parties for comprehensive business tax reform that can serve as the platform for economic growth while collecting appropriate levels of tax revenue. The arguments are ...


Cpa Exam Review May 2017

Cpa Exam Review

The Contemporary Tax Journal

No abstract provided.


Front Matter (Letter From The Editor, Masthead, Etc.) May 2017

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


Country By Country Reporting Under Beps, Fenny Lei May 2017

Country By Country Reporting Under Beps, Fenny Lei

The Contemporary Tax Journal

No abstract provided.


U.S. Tax Forms For American Expatriates, Saqib Amin Cpa May 2017

U.S. Tax Forms For American Expatriates, Saqib Amin Cpa

The Contemporary Tax Journal

No abstract provided.


Bringing The U.S. Tax Court Exam Out Of Obscurity, Lucia Nasuti Smeal J.D., Tad D. Ransopher J.D. May 2017

Bringing The U.S. Tax Court Exam Out Of Obscurity, Lucia Nasuti Smeal J.D., Tad D. Ransopher J.D.

The Contemporary Tax Journal

No abstract provided.


Summaries For The 32nd Annual Tei-Sjsu High Tech Tax Institute, Saqib Amin, Silin Chen, Ophelia Ding, Veena Hemachandran, Elle San Pedro De Kornsand, Padmini Yalamarthi, Yu Zheng May 2017

Summaries For The 32nd Annual Tei-Sjsu High Tech Tax Institute, Saqib Amin, Silin Chen, Ophelia Ding, Veena Hemachandran, Elle San Pedro De Kornsand, Padmini Yalamarthi, Yu Zheng

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal Volume 6, No. 2 – Spring 2017 May 2017

The Contemporary Tax Journal Volume 6, No. 2 – Spring 2017

The Contemporary Tax Journal

No abstract provided.


Capital Taxation In An Age Of Inequality, Edward D. Kleinbard May 2017

Capital Taxation In An Age Of Inequality, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

The standard view in the U.S. tax law academy remains that capital income taxation is both a poor idea in theory and completely infeasible in practice. But this ignores the first-order importance of political economy issues in the design of tax instruments. The pervasive presence of gifts and bequests renders moot the claim that the results obtained by Atkinson and Stiglitz (1976) counsel against taxing capital income in practice.

Taxing capital income is responsive to important political economy exigencies confronting the United States, including substantial tax revenue shortfalls relative to realistic government spending targets, increasing income and wealth inequality ...


Newsroom: Donald Trump Vs. Roger Williams 05-09-2017, David Logan May 2017

Newsroom: Donald Trump Vs. Roger Williams 05-09-2017, David Logan

Life of the Law School (1993- )

No abstract provided.


Rwu First Amendment Blog: David A. Logan's Blog: Donald Trump Vs. Roger Williams 05-08-2017, David A. Logan May 2017

Rwu First Amendment Blog: David A. Logan's Blog: Donald Trump Vs. Roger Williams 05-08-2017, David A. Logan

Law School Blogs

No abstract provided.


Statutory Interpretation Lessons Courtesy Of Pilgrim’S Pride, Philip G. Cohen May 2017

Statutory Interpretation Lessons Courtesy Of Pilgrim’S Pride, Philip G. Cohen

University of Miami Business Law Review

In Pilgrim’s Pride Corp. v. Commissioner, the Fifth Circuit reversed the Tax Court and held that the taxpayer was entitled to an ordinary loss deduction from its abandonment of securities. While the conclusion reached by the Fifth Circuit has been overshadowed by the promulgation of Treasury Regulation section 1.165-5(i) that effectively treats an abandoned security as worthless and thus characterizes the loss as capital, the case remains noteworthy because it provides an opportunity to examine the statutory interpretation of two distinct Internal Revenue Code sections, section 165(g)(1) and section 1234A. The article focuses on what ...


Taxation, Competitiveness, And Inversions: A Response To Kleinbard, Michael S. Knoll May 2017

Taxation, Competitiveness, And Inversions: A Response To Kleinbard, Michael S. Knoll

Faculty Scholarship

In this report, I argue that the inversion situation is more nuanced, complex, and ambiguous than Edward D. Kleinbard acknowledges, and I challenge Kleinbard’s claim that U.S. multinationals are on a tax par with their foreign competitors.