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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.
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 …
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 …
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.