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Articles 1 - 25 of 25
Full-Text Articles in Taxation-Federal
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 …
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'
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 …
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 …
Federal Taxation, Robert Beard
Federal Taxation, Robert Beard
Mercer Law Review
In 2013, several interesting federal tax cases were decided in the United States Court of Appeals for the Eleventh Circuit and in the United States Tax Court with decisions appealable to the Eleventh Circuit. These cases addressed the scope of the Internal Revenue Code (I.R.C.) § 83, the economic performance rules, and ownership of tax refunds in bankruptcy.
Tax Credit For Qualified Plug-In Electric Drive Motor Vehicle Purchases, Kara Virji-Gaidhar
Tax Credit For Qualified Plug-In Electric Drive Motor Vehicle Purchases, Kara Virji-Gaidhar
The Contemporary Tax Journal
No abstract provided.
Personal Service Versus Royalty Income For Athletes, Chanpheareak (Luis) Chim
Personal Service Versus Royalty Income For Athletes, Chanpheareak (Luis) Chim
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 3, No. 2 – Spring 2014
The Contemporary Tax Journal Volume 3, No. 2 – Spring 2014
The Contemporary Tax Journal
No abstract provided.
Tax Incentives To Move Jobs Back To The U.S., Gamaliel Salazar
Tax Incentives To Move Jobs Back To The U.S., Gamaliel Salazar
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview Of Pam Olson, Stuti Seth
The Contemporary Tax Journal’S Interview Of Pam Olson, Stuti Seth
The Contemporary Tax Journal
No abstract provided.
Income Or Liability: How Casinos' Classification Of Outstanding Chips Determine Taxability, John Bulloch
Income Or Liability: How Casinos' Classification Of Outstanding Chips Determine Taxability, John Bulloch
UNLV Gaming Law Journal
No abstract provided.
Unfair And Unintended: The Tax-Exempt Organization Blocker Loophole, Andrew M. Dougherty
Unfair And Unintended: The Tax-Exempt Organization Blocker Loophole, Andrew M. Dougherty
BYU Law Review
No abstract provided.
Wealth Transfer Tax Planning For 2013 And Beyond, John A. Miller, Jeffrey A. Maine
Wealth Transfer Tax Planning For 2013 And Beyond, John A. Miller, Jeffrey A. Maine
BYU Law Review
On January 1, 2013, Congress avoided the tax part of the so-called “fiscal cliff” when it passed the American Taxpayer Relief Act of 2012 (ATRA). Among its many impacts, ATRA prevented the application of a number of sunset provisions that would have dramatically altered the operation of the federal wealth transfer taxes. Instead, Congress made permanent two significant transfer tax provisions introduced as temporary measures in 2010: the $5,000,000 indexed basic exclusion amount and the deceased spousal unused exclusion amount. The latter provisions are sometimes referred to as the portability rules because, in effect, they allow one spouse’s estate tax …
States Versus Tribes: The Problem Of Multiple Taxation Of Non-Indian Oil And Gas Leases On Indian Reservations, Erin Marie Erhardt
States Versus Tribes: The Problem Of Multiple Taxation Of Non-Indian Oil And Gas Leases On Indian Reservations, Erin Marie Erhardt
American Indian Law Review
No abstract provided.
Retirement Security: Leveraging The Research And Development Tax Credit, Tristen J. Cohen
Retirement Security: Leveraging The Research And Development Tax Credit, Tristen J. Cohen
Marquette Elder's Advisor
The long-term health and stability of the social security program is currently being threatened by significant demographic shifts and petty political gamesmanship. The importance of the program combined with the significance of the chance of insolvency requires that some action be taken in the present to mitigate problems in the future. Congress can do this by decreasing benefits, raising taxes, or finding alternative ways to raise revenue. One such alternative is investing in program that will increase economic activity and productivity. This paper argues that the Startup Innovation Credit Act of 2013 leverages the research and development credit to create …
Consistency Is Key: To Preserve Legislative Intent The Irs Must Afford Legal Recognition To Non-Marital Relationships In A Post-Doma World, Shane R. Martins
Consistency Is Key: To Preserve Legislative Intent The Irs Must Afford Legal Recognition To Non-Marital Relationships In A Post-Doma World, Shane R. Martins
Marquette Elder's Advisor
Although the Supreme Court’s recent ruling in Windsor v. US allows for federal recognition of same-sex marriages, the Internal Revenue Service will only grant spousal recognition to couples residing in states that term same-sex unions as marriages. Consequently, spousal treatment will not be extended to non-marital relationships, even in states that treat their Civil Unions and Domestic Partnerships as “marital equivalents.” Given that spousal recognition for federal tax purposes was intended to ensure geographic uniformity and horizontal equity, the IRS must grant spousal recognition to couples who are in relationships that their respective state identifies as a “marital equivalent”.
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 …
Tax Accounting Myths, George Mundstock
Tax Accounting Myths, George Mundstock
University of Miami Business Law Review
No abstract provided.
Occupy Wall Street, Distributive Justice, And Tax Scholarship: An Ideology Critique Of The Consumption Tax Debate, Partrick Crawford
Occupy Wall Street, Distributive Justice, And Tax Scholarship: An Ideology Critique Of The Consumption Tax Debate, Partrick Crawford
The University of New Hampshire Law Review
[Excerpt] “This Article argues that the pro-consumption tax literature is wrong to claim that no legitimate fairness objections to the consumption tax exist. It argues that the persistent and widespread wariness about replacing our current hybrid consumption tax/income tax system with a pure consumption tax is, contrary to what the pro-consumption tax literature asserts, completely justified. In fact, our reservations about the consumption tax’s fairness reflect legitimate concern about the role of capitalist power in America, particularly over the past thirty years. Indeed, the more the nation continues to experience the social welfare effects of increased capitalist power, the more …
Financial Disability For All, T. Keith Fogg, Rachel E. Zuraw
Financial Disability For All, T. Keith Fogg, Rachel E. Zuraw
Catholic University Law Review
No abstract provided.