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Articles 1 - 30 of 129
Full-Text Articles in Taxation-Federal
Why Y? Reflections On The Baucus Proposal, Reuven S. Avi-Yonah
Why Y? Reflections On The Baucus Proposal, Reuven S. Avi-Yonah
Articles
The international tax reform proposal introduced by Sen. Max Baucus, D-Mont., on November 19 contains several significant innovations that promise to define the terms of the debate for the foreseeable political future. (Prior coverage: Tax Notes Int’l, Nov. 25, 2013, p. 691.) It is therefore worth examining in detail even if it seems unlikely that progress toward meaningful reform can be achieved very soon.
Watching The Watchers: Preventing I.R.S. Abuse Of The Tax System,, Samuel D. Brunson
Watching The Watchers: Preventing I.R.S. Abuse Of The Tax System,, Samuel D. Brunson
Samuel D. Brunson
As a result of broad outcries against the incompetence and aggressiveness of the LR.S., Congress reined in its behavior, requiring it to focus on treating taxpayers as customers. Congress also created oversight bodies to ensure that the I.R.S. would comply with the new mandate. Though those oversight bodies face some difficulties - most notably, the unwillingness of Congress to adequately fund them - they nonetheless have proven effective at checking the IR.S. 's misbehavior with regard to taxpayers. Congress has not, however been as solicitous to the tax law itself The I.R.S. can act in ways that violate both the …
Loving: Who Can The Irs Regulate?, Robert D. Probasco
Loving: Who Can The Irs Regulate?, Robert D. Probasco
Robert Probasco
Practice Before The Irs After The Restructuring And Reform Act, T. Keith Fogg, Robert E. Lee
Practice Before The Irs After The Restructuring And Reform Act, T. Keith Fogg, Robert E. Lee
T. Keith Fogg
No abstract provided.
Quoted In Tax Notes Today On Supreme Court Tax Decision, Robert D. Probasco
Quoted In Tax Notes Today On Supreme Court Tax Decision, Robert D. Probasco
Robert Probasco
No abstract provided.
Quoted In Daily Tax Report On Supreme Court Ruling On Gross Valuation Misstatement Penalty, Robert D. Probasco
Quoted In Daily Tax Report On Supreme Court Ruling On Gross Valuation Misstatement Penalty, Robert D. Probasco
Robert Probasco
No abstract provided.
How Stars Cases Apply Economic Substance Doctrine, Robert D. Probasco
How Stars Cases Apply Economic Substance Doctrine, Robert D. Probasco
Robert Probasco
Irs Gets Too Much Time To Go After Transferred Assets, Robert D. Probasco
Irs Gets Too Much Time To Go After Transferred Assets, Robert D. Probasco
Robert Probasco
Quoted In Daily Tax Report On 'Midco' Asset Transaction, Robert D. Probasco
Quoted In Daily Tax Report On 'Midco' Asset Transaction, Robert D. Probasco
Robert Probasco
No abstract provided.
Recent Developments & Tax Planning For High Income Taxpayers, Cameron N. Cosby, Brian J. O'Connor
Recent Developments & Tax Planning For High Income Taxpayers, Cameron N. Cosby, Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Are Back Pay And Damages In Age Discrimination Cases Subject To Income Taxes?, Matthew J. Barrett
Are Back Pay And Damages In Age Discrimination Cases Subject To Income Taxes?, Matthew J. Barrett
Matthew J. Barrett
No abstract provided.
Quoted In Reuters On Santander Ruling, Robert D. Probasco
Quoted In Reuters On Santander Ruling, Robert D. Probasco
Robert Probasco
No abstract provided.
A Review Of International Business Tax Reform, Alexander M. Lewis
A Review Of International Business Tax Reform, Alexander M. Lewis
University of Miami International and Comparative Law Review
No abstract provided.
The End Of Cash, The Income Tax, And The Next 100 Years, Gregg D. Polsky, Jeffery H. Kahn
The End Of Cash, The Income Tax, And The Next 100 Years, Gregg D. Polsky, Jeffery H. Kahn
Scholarly Works
The income tax is technologically very similar to the way it was in its early years, and technological developments have been at the margins of the income tax and have not affected its core elements. Still, technological improvements have made third-party reporting and withholding more efficient, which has allowed these mechanisms to become more pervasively used. Technology has also made it easier for taxpayers to substantiate their activities. These changes have facilitated the evolution of the incometax from its original class tax to the mass tax it is today.
While further technological advances might improve the federal income tax, it …
The Future Of Corporate Tax Reform: A Debate, Deborah A. Geier, Omni Y. Marian, David S. Miller, Adam H. Rosenzweig
The Future Of Corporate Tax Reform: A Debate, Deborah A. Geier, Omni Y. Marian, David S. Miller, Adam H. Rosenzweig
Law Faculty Articles and Essays
Professor Geier participated in a Lincoln-Douglas style debate, where the debaters were assigned different roles, so the opinions expressed were not necessarily their own. On the first point debated, Professor Geier was assigned to argue: The Affirmative: We Need to Tax Corporationsat the Entity Level. Others argued the negative: The United States Should Repeal the Corporate Income Tax. On the second point debated, Professor Geier argued the negative, that Dividend Exemption Is NOT the Best Method of Corporate/Shareholder Integration, and is in fact the worst method. On the third point, Professor Geier argued in the affirmative, that the corporate tax …
What Is A Return -- The Long Slow Fight In The Bankruptcy Courts, T. Keith Fogg
What Is A Return -- The Long Slow Fight In The Bankruptcy Courts, T. Keith Fogg
T. Keith Fogg
This article examines what constitutes a return within the context of a bankruptcy for purposes of allowing a taxpayer to discharge the tax debt.
Graev: Conditional Facade Easement, Wendy G. Gerzog
Graev: Conditional Facade Easement, Wendy G. Gerzog
All Faculty Scholarship
In Graev v. Commissioner, the Tax Court decided whether the taxpayers’ donations of a facade easement and cash contributions were conditional gifts and therefore disallowable as charitable deductions under the requirements of the regulations. The court reviewed the facts to determine whether the condition was allowed because it was “so remote as to be negligible.” The taxpayers argued that case law at the time of the donation allowed for a donation of between 10 and 15 percent of the value of the property, and that they had deducted a value constituting 11 percent of the property’s appraised value; that the …
Comments On Proposed Regulations Concerning List Maintenance Requirements, Robert D. Probasco, David Colmenero, Shawn O'Brien, Brandon Bloom
Comments On Proposed Regulations Concerning List Maintenance Requirements, Robert D. Probasco, David Colmenero, Shawn O'Brien, Brandon Bloom
Robert Probasco
Reinterpreting The Limited Partner Exclusion To Maximize Labor Income In The Self-Employment Tax Base , Laura E. Erdman
Reinterpreting The Limited Partner Exclusion To Maximize Labor Income In The Self-Employment Tax Base , Laura E. Erdman
Washington and Lee Law Review
No abstract provided.
Quoted In Reuters On Irs Relying On Economic Substance Doctrine, Robert D. Probasco
Quoted In Reuters On Irs Relying On Economic Substance Doctrine, Robert D. Probasco
Robert Probasco
No abstract provided.
Legal Mirrors Of Entrepreneurship, Mirit Eyal-Cohen
Legal Mirrors Of Entrepreneurship, Mirit Eyal-Cohen
Mirit Eyal-Cohen
Small businesses are regarded the engine of the economy. But just what is a “small” business? Depending on where one looks in the law, the definitions vary and they differ from one section to another. Unfortunately, what these various size classifications fail to assess, are the policy considerations and the legislative intent for granting regulatory preferences to small concerns to begin with.
In the last century, the U.S. government has been cultivating one such policy of fiscal and economic growth. Consequently, Congress and private institutions have been acting to incentivize, support and reward entrepreneurship through the law in order to …
Koons: Interest Deduction And Flp Valuation Practice Pointers, Wendy G. Gerzog
Koons: Interest Deduction And Flp Valuation Practice Pointers, Wendy G. Gerzog
All Faculty Scholarship
The Tax Court's Koons decision explains the rules for allowing an estate to deduct interest payments, and it details how the court arrived at a determination of the value of a family limited liability company interest.
What's Wrong With A Federal Inheritance Tax?, Wendy Gerzog
What's Wrong With A Federal Inheritance Tax?, Wendy Gerzog
Wendy Gerzog
Scholars have proposed a federal inheritance tax as an alternative to the current federal transfer tax system, but there are serious flaws with that idea. Those problems include: (1) different tax rates and exemptions based on the decedent’s relationship to the beneficiary; (2) the lack of a tax on lifetime gratuitous transfers, including gifts with retained interests or control; (3) the persistence of most current valuation distortion abuses; and (4) significantly decreased compliance rates and increased administrative costs inherent in a system that taxes transferees on transactions that may be largely unmonitored.
This article reviews common characteristics of existing inheritance …
What's Wrong With A Federal Inheritance Tax?, Wendy Gerzog
What's Wrong With A Federal Inheritance Tax?, Wendy Gerzog
Wendy Gerzog
Scholars have proposed a federal inheritance tax as an alternative to the current federal transfer tax system, but there are serious flaws with that idea. Those problems include: (1) different tax rates and exemptions based on the decedent’s relationship to the beneficiary; (2) the lack of a tax on lifetime gratuitous transfers, including gifts with retained interests or control; (3) the persistence of most current valuation distortion abuses; and (4) significantly decreased compliance rates and increased administrative costs inherent in a system that taxes transferees on transactions that may be largely unmonitored.
This article reviews common characteristics of existing inheritance …
The Taxation Of Cloud Computing And Digital Content, David Shakow
The Taxation Of Cloud Computing And Digital Content, David Shakow
All Faculty Scholarship
“Cloud computing” raises important and difficult questions in state tax law, and for Federal taxes, particularly in the foreign tax area. As cloud computing solutions are adopted by businesses, items we view as tangible are transformed into digital products. In this article, I will describe the problems cloud computing poses for tax systems. I will show how current law is applied to cloud computing and will identify the difficulties current approaches face as they are applied to this developing technology.
My primary interest is how Federal tax law applies to cloud computing, particularly as the new technology affects international transactions. …
Apple's Win Highlights Uncertainty In Valuing Tech Investments, Tom Hopkins, Kara Boatman
Apple's Win Highlights Uncertainty In Valuing Tech Investments, Tom Hopkins, Kara Boatman
The Contemporary Tax Journal
No abstract provided.
Nonqualified Use Of Principal Residence, Tejal Shah
Nonqualified Use Of Principal Residence, Tejal Shah
The Contemporary Tax Journal
No abstract provided.
Transferability Of The Research Tax Credit, Erika Codera
Transferability Of The Research Tax Credit, Erika Codera
The Contemporary Tax Journal
No abstract provided.
Return Of The 20% Capital Gains Rate For Certain High Income Individuals, Victoria Lau
Return Of The 20% Capital Gains Rate For Certain High Income Individuals, Victoria Lau
The Contemporary Tax Journal
No abstract provided.
Surtax On Millionaires, John Lowrie
Surtax On Millionaires, John Lowrie
The Contemporary Tax Journal
No abstract provided.