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Articles 1 - 30 of 76
Full-Text Articles in Taxation-Federal
Will States Step Up In 2020? We Hope So, Darien Shanske, David Gamage
Will States Step Up In 2020? We Hope So, Darien Shanske, David Gamage
Articles by Maurer Faculty
We offer no predictions about the next year in tax, but we will offer what we hope will happen — if not next year, then soon. To paraphrase Chief Justice John Roberts, we hope that when it comes to the taxation of multinational corporations in particular, states will act more like the “separate and independent sovereigns” that they are. often rely on volatile revenue sources. More stable tax bases, like the sales tax and the property tax bases, are riddled with design flaws, from the sales tax base not including services and intangibles to the property tax failing to provide …
A Current Update Of Epcrs Through Rev. Proc. 2019-19, 47 Tax Mgmt. Comp. Plan. J. 1 (Dec. 6, 2019), Kathryn J. Kennedy
A Current Update Of Epcrs Through Rev. Proc. 2019-19, 47 Tax Mgmt. Comp. Plan. J. 1 (Dec. 6, 2019), Kathryn J. Kennedy
UIC Law Open Access Faculty Scholarship
No abstract provided.
Tax Policy For The Wider Cryptoverse, Arild B. Doerge
Tax Policy For The Wider Cryptoverse, Arild B. Doerge
Student Scholarship
The rapid rise of Bitcoin and other “cryptoassets” offers many interesting technological capabilities but also comes with uncertainty and volatility in the markets for these assets. The diversity of types of cryptoassets is increasing rapidly, while public understanding and government policy have generally been slow to take account of this diversity. In regard to taxation policy related to cryptoassets, current IRS guidance merely categorizes cryptoassets as general property. The policy implications of this classification run contrary to fundamental goals of tax policy by inhibiting how people use cryptoassets, making compliance more complex and ambiguous than necessary, and taxing cryptoasset transactions …
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Buffalo Law Review
No abstract provided.
It’S All About The Drd, What’S Wrong With Foreign Branches, And A Few Other Things You Should Know About The New International Tax Provisions, Rebecca Rosenberg
It’S All About The Drd, What’S Wrong With Foreign Branches, And A Few Other Things You Should Know About The New International Tax Provisions, Rebecca Rosenberg
Loyola of Los Angeles Law Review
This Article highlights and analyzes some important points about the new international tax rules. For example, such provisions do not create an entirely territorial system. The partial movement towards territorial objectives is accomplished largely through the new 100% dividends received deduction (DRD) for certain foreign dividends from foreign corporations. However, this new DRD is much more limited in its application than most taxpayers may realize (for example, due to a very long holding period requirement). Even when the DRD potentially applies, taxpayers may attempt to claim foreign tax credits instead.
In addition, some of the new tax provisions show a …
Tax Attorneys As Defenders Of Taxpayer Rights, Michelle Lyon Drumbl
Tax Attorneys As Defenders Of Taxpayer Rights, Michelle Lyon Drumbl
Scholarly Articles
What is the modern role of a tax practitioner, in particular a tax attorney, in the United States? In an era in which the Internal Revenue Service (IRS) is underfunded, understaffed, and struggles to address its mission, tax attorneys play an important role as advocates for taxpayer rights.
Tax attorneys act as advocates who represent ordinary individual taxpayers in controversies with the IRS. These controversies include post-filing disputes, such as audits, as well as issues arising with the collection of assessed taxes. Many of these cases are resolved at the administrative level; those that cannot be resolved are litigated, most …
A Tax On The Clones: The Strange Case Of Bitcoin Cash, Eric D. Chason
A Tax On The Clones: The Strange Case Of Bitcoin Cash, Eric D. Chason
Faculty Publications
No abstract provided.
Table Of Contents, Seattle University Law Review
Table Of Contents, Seattle University Law Review
Seattle University Law Review
No abstract provided.
Why Pension Funding Matters, Eric D. Chason
The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason
The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason
Eric D. Chason
No abstract provided.
Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason
Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason
Eric D. Chason
No abstract provided.
Extending The Taxation-Of-Risk Model To Timing Options And Marked-To-Market Taxes, Eric D. Chason
Extending The Taxation-Of-Risk Model To Timing Options And Marked-To-Market Taxes, Eric D. Chason
Eric D. Chason
No abstract provided.
Law School News: Remembering Rwu Laws Founding Dean 9-10-2019, Roger Williams University School Of Law
Law School News: Remembering Rwu Laws Founding Dean 9-10-2019, Roger Williams University School Of Law
Life of the Law School (1993- )
No abstract provided.
Mormon Profit: Brigham Young, Tithing, And The Bureau Of Internal Revenue, Samuel D. Brunson
Mormon Profit: Brigham Young, Tithing, And The Bureau Of Internal Revenue, Samuel D. Brunson
BYU Law Review
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.)
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones, Inna Ostrovsky
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones, Inna Ostrovsky
The Contemporary Tax Journal
No abstract provided.
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute, Chen Chen, Liwei Bi, Surbhi Doshi
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute, Chen Chen, Liwei Bi, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
Summaries From The 34th Annual High Tech Tax Institute, Amy Yue Cpa, Langzun Li, Rachana Khandelwal, Nam Nguyen
Summaries From The 34th Annual High Tech Tax Institute, Amy Yue Cpa, Langzun Li, Rachana Khandelwal, Nam Nguyen
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill, Surbhi Doshi
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019
The Contemporary Tax Journal
No abstract provided.
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018, Inna Ostrovsky, Joanna Levasseur
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018, Inna Ostrovsky, Joanna Levasseur
The Contemporary Tax Journal
No abstract provided.
Roger Cpa Review Questions, Roger Philipp Cpa, Cgma
Roger Cpa Review Questions, Roger Philipp Cpa, Cgma
The Contemporary Tax Journal
No abstract provided.
Fun Tax Facts, Rachana Khandelwal
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress), Langzun Li
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress), Langzun Li
The Contemporary Tax Journal
No abstract provided.
Foreword, Michelle Lyon Drumbl
Foreword, Michelle Lyon Drumbl
Washington and Lee Journal of Civil Rights and Social Justice
Michelle L. Drumbl, Clinical Professor of Law and Director of the Tax Clinic at W&L Law, introduces this issue of the Journal of Civil Rights and Social Justice, which includes material presented at and inspired by the Journal's 2018 symposium, Always with Us? Poverty, Taxes, and Social Policy.
Converging Welfare States: Symposium Keynote, Susannah Camic Tahk
Converging Welfare States: Symposium Keynote, Susannah Camic Tahk
Washington and Lee Journal of Civil Rights and Social Justice
Susannah Camic Tahk, Associate Dean for Research and Faculty Development and Associate Professor of Law at the University of Wisconsin Law School, speaks to the Journal of Civil Rights and Social Justice 2018 symposium, Always with Us? Poverty, Taxes, and Social Policy. She addresses the following questions: To what extent do the particular advantages of the tax antipoverty programs persist as the tax antipoverty programs take center stage? Can tax programs, once distinguished from their direct-spending counterparts on the grounds of relative popularity and legal and administrative ease of access maintain those hallmarks as the tax-based welfare state grows …
A Typology Of Place-Based Investment Tax Incentives, Michelle D. Layser
A Typology Of Place-Based Investment Tax Incentives, Michelle D. Layser
Washington and Lee Journal of Civil Rights and Social Justice
This Article makes several contributions to tax, poverty, and empirical legal literature. First, it defines the category of place-based investment tax incentives and identifies key elements of variation across the category. Despite their prevalence at all levels of government, place-based investment tax incentives remain undertheorized and largely undefined in the literature. The typology presented here reflects an analysis of three federal tax incentives (the New Markets Tax Credit, the Low-Income Housing Tax Credit, and the new Opportunity Zones law) and a detailed survey of tax incentives included in state enterprise zone laws. By defining this category of tax laws and …
Dear I.R.S., It Is Time To Enforce The Campaigning Prohibition. Even Against Churches, Samuel Brunson
Dear I.R.S., It Is Time To Enforce The Campaigning Prohibition. Even Against Churches, Samuel Brunson
Samuel D. Brunson
In 1954, Congress prohibited tax-exempt public charities, including churches, from endorsing or opposing candidates for office. To the extent a tax-exempt public charity violated this prohibition, it would no longer qualify as tax-exempt, and the IRS was to revoke its exemption.
While simple in theory, in practice, the IRS rarely penalizes churches that violate the campaigning prohibition and virtually never revokes a church's tax exemption. And, because no taxpayer has standing to challenge the IRS's inaction, the IRS has no external imperative to revoke the exemptions of churches that do campaign on behalf of or against candidates for office.
This …
Taxing Utopia, Samuel Brunson
Taxing Utopia, Samuel Brunson
Samuel D. Brunson
Nineteenth-century American religious movements challenged many aspects of American society. Although their challenges to mainstream America's vision of sex and marriage remain the best-known aspects of many of these groups, their challenges to traditional American economics are just as important. Eschewing individual ownership of property, many of these new Christian movements followed the New Testament model of a body of believers that held all property in common.
In the early twentieth century, these religious communal groups had to contend with something new: an income tax. Communalism did not fit into the individualistic economic system envisioned b-y the drafters of the …
Free Money, But Not Tax-Free: A Proposal For The Tax Treatment Of Cryptocurrency Hard Forks, Danhui Xu
Free Money, But Not Tax-Free: A Proposal For The Tax Treatment Of Cryptocurrency Hard Forks, Danhui Xu
Fordham Law Review
Cryptocurrency has attracted extraordinary attention as one of the greatest financial innovations in recent years. Equally noticeable are the increasingly frequent cryptocurrency events, such as hard forks. Put simply, a cryptocurrency hard fork happens when a single cryptocurrency splits in two, which results in original coin owners receiving free forked coins. Such hard forks have resulted in billions of dollars distributed to U.S. taxpayers. Despite ongoing regulatory efforts, to date, the Internal Revenue Service (IRS) has yet to take a clear position on the tax treatment of cryptocurrency hard forks. The lack of useful guidance when filing tax returns has …