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Articles 1 - 30 of 116
Full-Text Articles in Taxation-Federal
When Helpers Hurt: Protecting Taxpayers From Preparers, Michelle Lyon Drumbl
When Helpers Hurt: Protecting Taxpayers From Preparers, Michelle Lyon Drumbl
Scholarly Articles
In this article, Drumbl explores return preparer regulation as a policy matter and questions what would be gained by applying Circular 230 to return preparers.
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert Green
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert Green
Robert A. Green
No abstract provided.
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
Robert A. Green
This background note consists of two parts. Part one provides an overview of the extent to which tax matters are currently covered in non-tax treaties. This discussion focuses on the general agreement on tariffs and trade (GATT)/World Trade Organization (WTO) agreement and the North American free trade agreement (NAFTA) (which cover direct tax measures only to a limited extent) and the European Community (EC) treaty (which covers direct tax measures more broadly). Part two outlines the issues raised when tax matters are covered in non-tax treaties.
Justice Blackmun's Federal Tax Jurisprudence, Robert A. Green
Justice Blackmun's Federal Tax Jurisprudence, Robert A. Green
Robert A. Green
During his tenure on the Supreme Court, Justice Blackmun was widely regarded as the Court's authority on tax matters. Justice Blackmun viewed tax law not merely as a technical specialty, but as a microcosm of the legal system. His numerous tax opinions involve a wide range of issues of constitutional law, criminal law, administrative procedure, court procedure, and statutory interpretation. This Article begins by discussing two of Justice Blackmun's tax opinions involving constitutional issues. Justice Blackmun refused to create special constitutional rules for tax cases. Instead, he applied generally applicable principles, but with great sensitivity to how those principles would …
Don't Leave Money On The Table! Irs [Mis]Computation Of Interest, Robert D. Probasco
Don't Leave Money On The Table! Irs [Mis]Computation Of Interest, Robert D. Probasco
Robert Probasco
No abstract provided.
The Matthew Effect And Federal Taxation, Martin J. Mcmahon Jr.
The Matthew Effect And Federal Taxation, Martin J. Mcmahon Jr.
Martin J. McMahon
The “Matthew Effect” is a synonym for the well-known colloquialism, “the rich get richer and the poor get poorer.” This Article is about the Matthew Effect in the distribution of incomes in the United States and the failure of the federal tax system to address the problem. There has been a strong Matthew Effect in incomes in the United States over the past few decades, with an increasing concentration of income and wealth in the top one percent. Nevertheless, there has been a continuing trend of enacting disproportionately large tax cuts for those at the top of the income pyramid. …
Taxing Risk: An Approach To Variable Insurance Reform, Charlene Luke
Taxing Risk: An Approach To Variable Insurance Reform, Charlene Luke
Charlene Luke
Variable life insurance and annuity contracts are susceptible to being marketed and sold to taxpayers for whom such contracts are unsuitable and to being used in wraparound insurance shelters. As a method of addressing these problems, I propose current taxation for the risky returns on these contracts but continued deferral for a deemed, risk-free return amount. The increased transparency resulting from the forced separate tax accounting of contract components should improve consumers' ability to receive adequate suitability evaluations and may also lead to lower fees. Current taxation of risk-related returns removes an apparently key shelter incentive and should make it …
Corporate Tax Aggressiveness - Recent History And Policy Options, Richard Harvey
Corporate Tax Aggressiveness - Recent History And Policy Options, Richard Harvey
Richard Harvey
No abstract provided.
Irs Tax Relief - Tips For Taxpayers - Tax Relief Programmes, Lissa Coffey Nyu School Of Law
Irs Tax Relief - Tips For Taxpayers - Tax Relief Programmes, Lissa Coffey Nyu School Of Law
LissaCoffey
IRS TAX RELIEF - TIPS FOR TAXPAYERS - TAX RELIEF PROGRAMMES ... it seems many of us look for ways to get more income back from the Internal Revenue Service (IRS) ... IRS Tax Relief Help ... will spot preventing the lies and tricks that agents sometimes use to try and cheat taxpayers who need vital reduced back taxes. Back Taxes : Settle Tax Debt and IRS Problems. Expiration of Back Taxes; IRS Help; IRS Tax Relief FAQs; Back Taxes: Settle Tax Debt and IRS Problems Owe IRS Back Taxes? ... Once an IRS Payment Plan (also known as an …
Charitable Deductions For Rail-Trail Conversions: Reconciling The Partial Interest Rule And The National Trails System Act, Scott Bowman, Danaya Wright
Charitable Deductions For Rail-Trail Conversions: Reconciling The Partial Interest Rule And The National Trails System Act, Scott Bowman, Danaya Wright
Danaya C. Wright
This Article examines an undeveloped legal topic at the intersection of tax law and real property law: charitable deductions from income tax liability for donations of railroad corridors that are to be converted into recreational trails. The very popular rails-to-trails program assists in the conversion of abandoned railroad corridors into hiking and biking trails. However, the legal questions surrounding the property rights of these corridors have been complex and highly litigated. In 1983, Congress amended the National Trails System Act to provide a mechanism for facilitating these conversions, a process called railbanking. In essence, a railroad transfers its real property …
Speak Up: Issue Advocacy In Increasingly Politicized Times, Sally Wagenmaker
Speak Up: Issue Advocacy In Increasingly Politicized Times, Sally Wagenmaker
The Journal of Business, Entrepreneurship & the Law
This article first provides a brief primer on current constraints affecting Section 501(c)(3) and 501(c)(4) organizations' communications within the context of what has become known as “issue advocacy.” It then sets forth the problem of increasing politicization of nonprofits' issue advocacy activities. The article next evaluates related constitutional tensions for politically tinged issue advocacy, through the lens of the Supreme Court's free speech decisions. It concludes by addressing how the IRS's different content-based standards for issue advocacy are susceptible to abuse, are otherwise constitutionally suspect, and therefore warrant reform.
Reinvigorating The Reit's Neutrality And Capital Formation Purposes Through A Modernized Tax Integration Model, Simon Johnson
Reinvigorating The Reit's Neutrality And Capital Formation Purposes Through A Modernized Tax Integration Model, Simon Johnson
The Journal of Business, Entrepreneurship & the Law
Efforts at reform have not spared the REIT arrangement, but have focused on objectives unrelated to its model of tax integration, despite its significant flaws. Owing to the interaction of several provisions, the model largely precludes capitalization through retained earnings. This increases the cost of REIT capital and limits its capacity to realize the neutrality and private real estate capital formation objectives Congress pursued in creating the arrangement. Accordingly, it is important to consider how to durably improve the REIT tax integration model. Ultimately, the article concludes that the shareholder allocation model, a complete integration model conceptually similar to the …
Tax Debt Help – Settlement & Negotiation, Lissa Coffey
Tax Debt Help – Settlement & Negotiation, Lissa Coffey
LissaCoffey
Get helpful tips, advice and help with debt or any kind of irs help on setting up payment plans, requesting affordable installment agreements, reducing your tax debts through an Offer in Compromise, or discharging your tax debts through bankruptcy. Tags: GET-OUT-OF-IRS-TAX-DEBT, irs tax help, tax relief help, IRS-PAYMENT-PLAN, irs debt, irs help, help with debt, help with tax debt
Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen
Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen
William & Mary Annual Tax Conference
No abstract provided.
Net Investment Income Tax Planning, Jeanne M. Sullivan
Net Investment Income Tax Planning, Jeanne M. Sullivan
William & Mary Annual Tax Conference
No abstract provided.
The Contemporary Tax Journal Volume 4, No. 1 – Fall 2014
The Contemporary Tax Journal Volume 4, No. 1 – Fall 2014
The Contemporary Tax Journal
No abstract provided.
An Examination Of The Tax Incentive For Child Support, Gary M. Fleischman, Paul Hutchison, Zafar Dad Khan
An Examination Of The Tax Incentive For Child Support, Gary M. Fleischman, Paul Hutchison, Zafar Dad Khan
The Contemporary Tax Journal
No abstract provided.
‘Coin’Ing The Tax ‘Bit’, Asmita Bedekar
‘Coin’Ing The Tax ‘Bit’, Asmita Bedekar
The Contemporary Tax Journal
No abstract provided.
Why Section 530 Of The Revenue Act Of 1978 Applies To The States, David Randall Jenkins
Why Section 530 Of The Revenue Act Of 1978 Applies To The States, David Randall Jenkins
The Contemporary Tax Journal
No abstract provided.
Pro And Con (Law): Considering The Irrevocable Nongrantor Trust Technique, Alyssa A. Dirusso
Pro And Con (Law): Considering The Irrevocable Nongrantor Trust Technique, Alyssa A. Dirusso
Vanderbilt Law Review
Commentary on Jeffrey Schoenblum, Strange Bedfellows: The Federal Constitution, Out-of-State Nongrantor Accumulation Trusts, and the Complete Avoidance of State Income Taxation'
The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson
The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson
John Ferguson
No abstract provided.
Pro & Con: Should Congress Adopt A New Tax Credit For Buying A Home? Yes: No Recovery Is Possible If Homeowners Lose Their Homes, Jessica D. Gabel
Pro & Con: Should Congress Adopt A New Tax Credit For Buying A Home? Yes: No Recovery Is Possible If Homeowners Lose Their Homes, Jessica D. Gabel
Jessica Gabel Cino
No abstract provided.
Integrating Subchapters K And S And Beyond, Walter D. Schwidetzky
Integrating Subchapters K And S And Beyond, Walter D. Schwidetzky
All Faculty Scholarship
This Article builds upon a similar, lengthier effort that I published in the Tax Lawyer in 2009. While there is overlap, this Article contains much new material. Important case law and tax proposals from the House Ways and Means Committee have come out in the interim. Due to space limitations, unlike my Tax Lawyer effort, this Article attempts to avoid prolixity. It assumes the reader has good knowledge of both Subchapters S and K and the tax entity selection process. If you are not that reader, a review of my Tax Lawyer article or Professor Mann's article in this symposium …
Study Of The Role Of Preparers In Relation To Taxpayer Compliance With Internal Revenue Laws, Leslie Book
Study Of The Role Of Preparers In Relation To Taxpayer Compliance With Internal Revenue Laws, Leslie Book
Leslie Book
The use of paid tax return preparers has grown steadily. All paid return preparers, including those who are not regulated by any licensing entity or subject to competency or continuing education requirements, must comply with certain requirements in connection with the preparation of a tax return, including signing the return and providing a copy of the return to taxpayers. Preparers are also subject to civil and even criminal penalties for improper conduct and the Code provides that the United States may bring a civil action to enjoin tax preparers if preparers engage in certain types of impermissible conduct.
As discussed …
The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson
The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson
John Ferguson
No abstract provided.
Formulary Appointment In The U.S. International Income Tax System: Putting Lipstick On A Pig?, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Formulary Appointment In The U.S. International Income Tax System: Putting Lipstick On A Pig?, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Michigan Journal of International Law
An affiliated corporate group consists of two or more corporations linked by sufficient stock ownership to cause them to function as an economic unit instead of as independent economic actors. Thus, an affiliated corporate group engaged in international business is often referred to as a multinational enterprise (MNE), a term that we will use throughout this Article. When corporate members of an MNE engage in transactions among themselves, the prices they employ (transfer prices) will significantly affect the amount of overall MNE income that is allocated to each member and, hence, to the tax bases of the various countries in …
The Origins Of Affirmative Fiscal Action, Mirit Eyal-Cohen
The Origins Of Affirmative Fiscal Action, Mirit Eyal-Cohen
Mirit Eyal-Cohen
This article highlights an anomaly. It shows that two tax rules aimed to achieve a similar goal were introduced at the same time. Both meant to be temporary and bring economic stimuli, but received a dramatically different treatment. The less efficient or economically inferior survived. Its superior counterpart did not. The article reviews the reasons for this paradox. It shows that the reason is both political and an agency problem. The article not only enriches an important and ongoing debate that has received much attention in recent years, but also provides important lessons to policymakers.
Revenue, U.S. Government, Bert Chapman
Revenue, U.S. Government, Bert Chapman
Libraries Faculty and Staff Scholarship and Research
Provides a historical overview of U.S. Government revenue receipts and spending during the early years of national history. Presents revenue generation statistics, information on revenue sources, and information on domestic and international political and economic factors affecting government revenue receipts.
Mutual Funds, Fairness, And The Income Gap, Samuel D. Brunson
Mutual Funds, Fairness, And The Income Gap, Samuel D. Brunson
Samuel D. Brunson
The rich, it turns out, are different from the rest of us. The wealthy, for example, can assemble a diversified portfolio of securities or can invest through hedge and private equity funds. When the rest of us invest, we do so largely through mutual funds. Nearly half of American households own mutual funds, and mutual funds represent a significant portion of the financial assets held by U.S. households. The tax rules governing mutual funds create an investment vehicle with significantly worse tax treatment than investments available to the wealthy. In particular, the tax rules governing mutual funds force shareholders to …
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham
Pace Law Review
In order to promote both equality and efficiency, this Comment proposes that individuals should have the opportunity to file jointly for tax and bankruptcy purposes when they have a relationship predicated upon economic interdependence, as opposed to basing the opportunity to file jointly upon marital status. Part I of this Comment will briefly discuss the history of marriage in the United States. In particular, Part I will discuss the role that the government has had in promoting and regulating marriage and how the treatment of married persons operates to the exclusion of the unmarried. Parts II and III of this …