Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Taxation-Federal
A Tax Deduction For Direct Charitable Transfers: The Case Against Davis V. United States, 861 F.2d 558 (9th Cir. 1988), David L. Herron
A Tax Deduction For Direct Charitable Transfers: The Case Against Davis V. United States, 861 F.2d 558 (9th Cir. 1988), David L. Herron
Washington Law Review
Monetary transfers to charitable service providers may be deductible either as charitable contributions or as unreimbursed expenses. Whether a charity must possess the transfer to establish the charity control necessary to effect a charitable deduction is an unresolved issue. Using direct transfers to Mormon missionaries in Davis v. United States as an example, this Note concludes that direct transfers to service providers should be deductible and proposes a test for determining when charity control is sufficient without possession.
Income Taxation Of Distributions Made By Alaska Native Corporations: An Ambiguity In Need Of Clarification, Meade Emory, Robert A. Warden
Income Taxation Of Distributions Made By Alaska Native Corporations: An Ambiguity In Need Of Clarification, Meade Emory, Robert A. Warden
Washington Law Review
In 1971, Congress passed the Alaska Native Claims Settlement Act ("ANCSA") to provide compensation for extinguishing Native land claims in Alaska. ANCSA created a system of village corporations that received money and land as compensation, and are to distribute the compensation to shareholders. The Internal Revenue Service ("IRS"), despite legislative history to the contrary, is now asserting that corporate tax principles apply to the distributions because of ambiguous language contained in ANCSA. This assertion makes distributions to shareholders taxable as dividends to the extent of the corporations' accumulated and current earnings and profits. The IRS stance will result in excessive …