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Articles 1 - 5 of 5
Full-Text Articles in Taxation-Federal
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 …
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 …
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.
A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie H. Mcmahon
A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie H. Mcmahon
Faculty Articles and Other Publications
ABSTRACT-Conceptions of property exist on a spectrum between the Blackstonian absolute dominion over an object to a bundle of rights and obligations that recognizes, if not encourages, the splitting of property interests among different people. The development of the bundle of rights conception of property occurred in roughly the same era as the enactment of the modem federal income tax. Nevertheless, when Congress enacted the tax in 1913, it did not consider how the nuances of property, and the possible splitting of the interests in an income-producing item, might affect application of the tax. Soon after the tax's enactment, the …
Promise Vs. Performance: Why Public Subsidies Of Private Development Are Not Likely To Produce Fair Returns To The Taxpaying Public, Marc Knapp
University of Baltimore Journal of Land and Development
On September 10, 2013, the Baltimore City Council gave final approval to Harbor Point, a $1 billion multi-use project to be built on a vacant, remediated brownfield that juts into Baltimore's Inner Harbor. Like many urban development or redevelopment projects, Harbor Point will be supported by significant taxpayer subsidies. Between a $107 million direct investment in project-related infrastructure largely parks that will surround the to-be-built offices, shops and residences, and a waterfront promenade - along with a mixed bag of real estate and income tax incentives, the visible public support to Harbor Point will exceed $200 million, 20% of projected …