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Washington and Lee Law Review

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Full-Text Articles in Taxation-Federal

Tax Reporting As Regulation Of Digital Financial Markets, Young Ran (Christine) Kim Jul 2023

Tax Reporting As Regulation Of Digital Financial Markets, Young Ran (Christine) Kim

Washington and Lee Law Review

FTX’s recent collapse highlights the overall instability that blockchain assets and digital financial markets face. While the use of blockchain technology and crypto assets is widely prevalent, the associated market is still largely unregulated, and the future of digital asset regulation is also unclear. The lack of clarity and regulation has led to public distrust and has called for more dedicated regulation of digital assets. Among those regulatory efforts, tax policy plays an important role. This Essay introduces comprehensive regulatory frameworks for blockchain-based assets that have been introduced globally and domestically, and it shows that tax reporting is the key …


Fake News And The Tax Law, Kathleen Delaney Thomas, Erin Scharff Apr 2023

Fake News And The Tax Law, Kathleen Delaney Thomas, Erin Scharff

Washington and Lee Law Review

The public misunderstands many aspects of the tax system. For example, people frequently misunderstand how marginal tax rates work, misperceive their own average tax rates, and believe they benefit from tax deductions for which they are ineligible. Such confusion is understandable given the complexity of our tax laws. Unfortunately, research suggests these misconceptions shape voter preferences about tax policy which, in turn, impact the policies themselves.

That people are easily confused by taxes is nothing new. With the rise of social media platforms, however, the speed at which misinformation campaigns can now move to shape public opinion is far faster. …


The Surprising Significance Of De Minimis Tax Rules, Leigh Osofsky, Kathleen Delaney Thomas Apr 2021

The Surprising Significance Of De Minimis Tax Rules, Leigh Osofsky, Kathleen Delaney Thomas

Washington and Lee Law Review

De minimis tax rules—rules that eliminate tax burdens for low-income taxpayers or low-dollar transactions—abound in the tax law. Despite the prevalence of such rules, legal scholarship has treated them as—well—de minimis, or as mere rounding errors that do not merit sustained attention. This perspective is understandable. If de minimis rules address insignificant taxpayers or tax liabilities, aren’t the rules themselves likely to be insignificant?

Recent tax law developments have revealed that this conception of de minimis tax rules is deeply misguided. Major allocations of tax law liability, as well as accompanying questions about the fairness, efficiency, and administrability of the …


The Practice And Tax Consequences Of Nonqualified Deferred Compensation, David I. Walker Feb 2019

The Practice And Tax Consequences Of Nonqualified Deferred Compensation, David I. Walker

Washington and Lee Law Review

Although nonqualified deferred compensation plans lack explicit tax preferences afforded to qualified plans, it is well understood that nonqualified deferred compensation results in a joint tax advantage when employers earn a higher after-tax return on deferred sums than employees could achieve on their own. But the joint tax advantage depends critically on how plans are operated; chiefly how plan sponsors use or invest deferred compensation dollars. This is the first Article to systematically investigate nonqualified deferred compensation practices. It shows that joint tax minimization historically has taken a backseat to accounting priorities and participant diversification concerns. In recent years, the …


Reinterpreting The Limited Partner Exclusion To Maximize Labor Income In The Self-Employment Tax Base , Laura E. Erdman Sep 2013

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.


The Physical Consequences Of Emotional Distress: The Need For A New Test To Determine What Amounts Are Excluded From Gross Income Under § 104(A)(2), C. Anthony Wolfe Iv Sep 2012

The Physical Consequences Of Emotional Distress: The Need For A New Test To Determine What Amounts Are Excluded From Gross Income Under § 104(A)(2), C. Anthony Wolfe Iv

Washington and Lee Law Review

No abstract provided.


Fatca: Toward A Multilateral Automatic Information Reporting Regime, Joanna Heiberg Jun 2012

Fatca: Toward A Multilateral Automatic Information Reporting Regime, Joanna Heiberg

Washington and Lee Law Review

No abstract provided.


United States V. Textron: The Right Answer To A Billion-Dollar Question, Ned Hillenbrand Sep 2011

United States V. Textron: The Right Answer To A Billion-Dollar Question, Ned Hillenbrand

Washington and Lee Law Review

No abstract provided.


The Unintended Tax Advantages Of Gay Marriage, Theodore P. Seto Sep 2008

The Unintended Tax Advantages Of Gay Marriage, Theodore P. Seto

Washington and Lee Law Review

The Internal Revenue Code (the Code) contains numerous special rules applicable to the income taxation of persons related by marriage, birth, adoption, or ownership. This Article suggests a new approach to their analysis. Many basic tax rules assume that taxpayers are self-interested and unaffiliated. Where this assumption is incorrect, the Code makes adjustments to its otherwise applicable rules. Most of the resulting related-party antiavoidance rules apply only in the context of specified formal relationships-marriage, parent/child, or owner/business. The Article tests this thesis by comparing the income tax treatment of heterosexual married couples with that of gay couples in committed long-term …


Controlling Executive Compensation Through The Tax Code, Gregg D. Polsky Jun 2007

Controlling Executive Compensation Through The Tax Code, Gregg D. Polsky

Washington and Lee Law Review

No abstract provided.


Saving The Family Farm Through Federal Tax Policy: Easier Said Than Done Alex, Alex E. Snyder Mar 2005

Saving The Family Farm Through Federal Tax Policy: Easier Said Than Done Alex, Alex E. Snyder

Washington and Lee Law Review

No abstract provided.


Return To Sharecropping: Lawyers And Clients As Tenants And Landlords In The Tax Treatment Of Contingency Fees, Dean T. Howell Mar 2002

Return To Sharecropping: Lawyers And Clients As Tenants And Landlords In The Tax Treatment Of Contingency Fees, Dean T. Howell

Washington and Lee Law Review

No abstract provided.


What Part Of Rpos Don't You Understand? An Update And Survey Of Standards For Tax Return Positions, J. Timothy Philipps, Michael W. Mumbach, Morgan W. Alley Sep 1994

What Part Of Rpos Don't You Understand? An Update And Survey Of Standards For Tax Return Positions, J. Timothy Philipps, Michael W. Mumbach, Morgan W. Alley

Washington and Lee Law Review

No abstract provided.


Federal Taxation Of Prepaid College Tuition Plans, J. Timothy Philipps Mar 1990

Federal Taxation Of Prepaid College Tuition Plans, J. Timothy Philipps

Washington and Lee Law Review

No abstract provided.


But Reverend, Why Does Your Baptismal Font Have A Diving Board? Equitable Treatment For Vows Of Poverty Under The Federal Income Tax , J. Timothy Philipps Jan 1987

But Reverend, Why Does Your Baptismal Font Have A Diving Board? Equitable Treatment For Vows Of Poverty Under The Federal Income Tax , J. Timothy Philipps

Washington and Lee Law Review

No abstract provided.


Abusive Tax Shelters After The Tax Reform Act Of 1984 Jan 1985

Abusive Tax Shelters After The Tax Reform Act Of 1984

Washington and Lee Law Review

No abstract provided.


Greater Efficiency Or Higher Consumer Rates? Fcc Preemption Of State Depreciation Methods For Telephone Companies In Virginia State Corporation Commission V. Fcc Jan 1985

Greater Efficiency Or Higher Consumer Rates? Fcc Preemption Of State Depreciation Methods For Telephone Companies In Virginia State Corporation Commission V. Fcc

Washington and Lee Law Review

No abstract provided.


Blowing Hot And Cold At The Same Time: Section 1034 Rollover And Rental Deductions On Rental And Sale Of Principal Residence Sep 1984

Blowing Hot And Cold At The Same Time: Section 1034 Rollover And Rental Deductions On Rental And Sale Of Principal Residence

Washington and Lee Law Review

No abstract provided.


Medically Necessitated Meal And Lodging Costs: Should They Be Deductible Under Internal Revenue Code Section 213?, J. Timothy Philipps, Kenneth B. Tillou Mar 1984

Medically Necessitated Meal And Lodging Costs: Should They Be Deductible Under Internal Revenue Code Section 213?, J. Timothy Philipps, Kenneth B. Tillou

Washington and Lee Law Review

No abstract provided.


Recent Developments Affecting The Income And Gift Tax Consequences Of Interest-Free Loans Sep 1983

Recent Developments Affecting The Income And Gift Tax Consequences Of Interest-Free Loans

Washington and Lee Law Review

No abstract provided.


Tax-Exempt Status Of Amateur Sports Organizations Sep 1983

Tax-Exempt Status Of Amateur Sports Organizations

Washington and Lee Law Review

No abstract provided.


State Taxation Of Nondomiciliary Corporations Jan 1983

State Taxation Of Nondomiciliary Corporations

Washington and Lee Law Review

No abstract provided.


Clarifying The Characteristics Of Brother-Sister Controlled Groups Of Corporations: United States V. Vogel Fertilizer Co. Sep 1982

Clarifying The Characteristics Of Brother-Sister Controlled Groups Of Corporations: United States V. Vogel Fertilizer Co.

Washington and Lee Law Review

No abstract provided.


Small Issue Industrial Development Bonds: The Growing Abuse Jan 1982

Small Issue Industrial Development Bonds: The Growing Abuse

Washington and Lee Law Review

No abstract provided.


B Reorganizations: The Voting Stock Rule Revisited Jan 1981

B Reorganizations: The Voting Stock Rule Revisited

Washington and Lee Law Review

No abstract provided.


Tax Breaks For Law Students Jan 1981

Tax Breaks For Law Students

Washington and Lee Law Review

No abstract provided.


Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976 Jan 1979

Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976

Washington and Lee Law Review

No abstract provided.


Are Partnerships Aggregates Or Entities When Determining The Availability Of Investment Credit For Used Property? Sep 1978

Are Partnerships Aggregates Or Entities When Determining The Availability Of Investment Credit For Used Property?

Washington and Lee Law Review

No abstract provided.


Bank Credit Cards And The Timing Of Deductions Under Revenue Ruling 78-38: A Return To Consistency Sep 1978

Bank Credit Cards And The Timing Of Deductions Under Revenue Ruling 78-38: A Return To Consistency

Washington and Lee Law Review

No abstract provided.


Incorporating A Cash Basis Business: The Problem Of Section 357© Jan 1977

Incorporating A Cash Basis Business: The Problem Of Section 357©

Washington and Lee Law Review

No abstract provided.