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Articles 1 - 11 of 11
Full-Text Articles in Taxation-Federal
The Impact Of The United States Tax Laws On International Technology Transfer: An Overview And Some Suggestion For Minimizing The Bite, Marcus B. Finnegan, Robert E. Mccarthy
The Impact Of The United States Tax Laws On International Technology Transfer: An Overview And Some Suggestion For Minimizing The Bite, Marcus B. Finnegan, Robert E. Mccarthy
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Georgia Journal of International & Comparative Law
No abstract provided.
Through The Antiboycott Morass To An Export Priority, Mark D. Menefee, Don Samuel
Through The Antiboycott Morass To An Export Priority, Mark D. Menefee, Don Samuel
Georgia Journal of International & Comparative Law
No abstract provided.
Deciphering The Supreme Court's Opinion In Wynne, Walter Hellerstein
Deciphering The Supreme Court's Opinion In Wynne, Walter Hellerstein
Scholarly Works
In Wynne, the Supreme Court held that Maryland's personal income tax regime violated the dormant Commerce Clause because It taxed income on a residence and source basis without giving a credit to residents for in· come taxed on a source basis by other states. The Court suggested, how· ever, that a state may tax residents on all their Income without providing a credit for taxes paid by other states if the state did not tax nonresidents on income from sources within the state, even though such a taxing regime might result in double taxation of interstate commerce.
Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram
Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii
Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii
Georgia Journal of International & Comparative Law
No abstract provided.
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Georgia Journal of International & Comparative Law
No abstract provided.
Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.
Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.
Georgia Journal of International & Comparative Law
No abstract provided.
Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne
Georgia Journal of International & Comparative Law
No abstract provided.
Structural Tax Exceptionalism, James M. Puckett
Structural Tax Exceptionalism, James M. Puckett
Georgia Law Review
Following the Supreme Court's landmark decision in Mayo Foundation for Medical Education and Research v. United States, many scholars of tax law have declared that Mayo marks the death of tax exceptionalism. The tax exceptionalist view holds that because tax is different or special, generally applicable administrative law procedural rules and doctrines do not apply in the tax context. In Mayo, however, the Supreme Court held that generally applicable administrative law rules and doctrines do apply to the Treasury Department and the IRS. Contrary to the prevailing narrative that proclaims the death of tax exceptionalism, this Article posits that the …
Taxing Compensatory Stock Rights Transferred In Divorce, Gregg Polsky, Kathleen Delaney Thomas
Taxing Compensatory Stock Rights Transferred In Divorce, Gregg Polsky, Kathleen Delaney Thomas
Scholarly Works
Stock-based compensation has become increasingly prevalent in recent years. As a result, many high net worth divorces now result in the transfer of compensatory stock rights from the employee spouse to the nonemployee spouse as part of the marital settlement. Despite this growing trend, the tax consequences of these transfers have not yet been explored fully. This Article endeavors to fill this void and explain both the planning opportunities and potential pitfalls in transferring compensatory stock rights in divorce. These transfers can shift ordinary income from a high-bracket spouse to a lower-bracket spouse, creating a tax surplus that enlarges the …