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Business Taxes Reinvented: A Term Sheet, Edward D. Kleinbard 2017 University of Southern California

Business Taxes Reinvented: A Term Sheet, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

This short overview and accompanying term sheet summarize the key features of a proposed comprehensive business tax environment termed the Dual Business Enterprise Income Tax (the Dual BEIT). The term sheet format is a useful mode of presentation for capturing in one accessible document the major policy recommendations of the Dual BEIT (or any other comprehensive tax reform proposal).

This paper makes the case that the Dual BEIT satisfies the objectives of policymakers from both parties for comprehensive business tax reform that can serve as the platform for economic growth while collecting appropriate levels of tax revenue. The arguments are ...


From Student-Athletes To Employee-Athletes: Why A "Pay For Play" Model Of College Sports Would Not Necessarily Make Educational Scholarships Taxable, Marc Edelman 2017 City University of New York

From Student-Athletes To Employee-Athletes: Why A "Pay For Play" Model Of College Sports Would Not Necessarily Make Educational Scholarships Taxable, Marc Edelman

Boston College Law Review

In recent years, numerous commentators have called for the National Collegiate Athletic Association (“NCAA”) to relax its rules prohibiting athlete pay. This movement to allow athletes to share in the revenues of college sports arises from the belief that college athletes sacrifice too much time, personal autonomy, and physical health to justify their lack of pay. It further criticizes the NCAA’s “no pay” rules for keeping the revenues derived from college sports “in the hands of a select few administrators, athletic directors, and coaches.” Nevertheless, opponents of “pay for play” contend that several problems will emerge from lifting the ...


Discrete Tax Issues For Clergy And Religious, Deirdre A. Dessingue, Esq. 2017 St. John's University School of Law

Discrete Tax Issues For Clergy And Religious, Deirdre A. Dessingue, Esq.

The Catholic Lawyer

No abstract provided.


Constitutionality Of Legislation Denying Tax Exempt Status To Racially Discriminatory Schools, Eileen M. Hanrahan, Esq. 2017 St. John's University School of Law

Constitutionality Of Legislation Denying Tax Exempt Status To Racially Discriminatory Schools, Eileen M. Hanrahan, Esq.

The Catholic Lawyer

No abstract provided.


Tax Exemption And Racial Discrimination, John A. Liekweg, Esq. 2017 St. John's University School of Law

Tax Exemption And Racial Discrimination, John A. Liekweg, Esq.

The Catholic Lawyer

No abstract provided.


An Overview Of The Tax Status Of Exempt Organizations, Milton Cerny, Esq., Exempt Organizations, Internal Revenue Service 2017 St. John's University School of Law

An Overview Of The Tax Status Of Exempt Organizations, Milton Cerny, Esq., Exempt Organizations, Internal Revenue Service

The Catholic Lawyer

No abstract provided.


Taxing Prizes And Awards: Proposed Amendments To Section 74 To Treat Meritorious Achievements Equitably, Tayler Green 2017 Southern Methodist University

Taxing Prizes And Awards: Proposed Amendments To Section 74 To Treat Meritorious Achievements Equitably, Tayler Green

SMU Law Review

No abstract provided.


Internal Revenue Service Developments, Deirdre A. Dessingue, Assistant General Counsel, United States Catholic Conference 2017 St. John's University School of Law

Internal Revenue Service Developments, Deirdre A. Dessingue, Assistant General Counsel, United States Catholic Conference

The Catholic Lawyer

No abstract provided.


Report On Tax And Litigation Developments, George E. Reed, Consultant, Office of the General Counsel, United States Catholic Conference 2017 St. John's University School of Law

Report On Tax And Litigation Developments, George E. Reed, Consultant, Office Of The General Counsel, United States Catholic Conference

The Catholic Lawyer

No abstract provided.


Revenue Ruling 78-248, Thomas A. Horkan, Executive Director, Florida Catholic Conference 2017 St. John's University School of Law

Revenue Ruling 78-248, Thomas A. Horkan, Executive Director, Florida Catholic Conference

The Catholic Lawyer

No abstract provided.


Revenue Ruling 78-248: The Congress And The Constitution Be Damned, Alfred L. Scanlan, Shea & Gardner, Washington, D.C. 2017 St. John's University School of Law

Revenue Ruling 78-248: The Congress And The Constitution Be Damned, Alfred L. Scanlan, Shea & Gardner, Washington, D.C.

The Catholic Lawyer

No abstract provided.


Tax Exemptions Of Private Schools - The Impact Of Internal Revenue Service Proposals On The Catholic School System, John S. Nolan, Miller and Chevalier, Washington, D.C. 2017 St. John's University School of Law

Tax Exemptions Of Private Schools - The Impact Of Internal Revenue Service Proposals On The Catholic School System, John S. Nolan, Miller And Chevalier, Washington, D.C.

The Catholic Lawyer

No abstract provided.


Update On Unemployment Compensation, Thomas A. Rayer, Denechaud & Denechaud, New Orleans, Louisiana 2017 St. John's University School of Law

Update On Unemployment Compensation, Thomas A. Rayer, Denechaud & Denechaud, New Orleans, Louisiana

The Catholic Lawyer

No abstract provided.


The Right Tax At The Right Time, Edward D. Kleinbard 2017 University of Southern California

The Right Tax At The Right Time, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

The companion paper to this (Capital Taxation in an Age of Inequality) argues that a moderate flat-rate (proportional) income tax on capital imposed and collected annually has attractive theoretical and political economy properties that can be harnessed in actual tax instrument design. This paper continues the analysis by specifying in detail how such a tax might be designed.

The idea of the Dual Business Enterprise Income Tax, or Dual BEIT, is to offer business enterprises a neutral profits tax environment in which to operate, in which normal returns to capital are exempt from tax by means of an annual capital ...


Federal Tax Law: The Costs Of Cliff Effects In The Internal Revenue Code, Manoj Viswanathan 2017 University of California, Hastings College of the Law

Federal Tax Law: The Costs Of Cliff Effects In The Internal Revenue Code, Manoj Viswanathan

The Judges' Book

No abstract provided.


Proposed Internal Revenue Service Procedure Regarding Revocation Of Tax Exempt Status For Private Schools Which Discriminate On The Basis Of Race, David L. Anderson 2017 St. John's University School of Law

Proposed Internal Revenue Service Procedure Regarding Revocation Of Tax Exempt Status For Private Schools Which Discriminate On The Basis Of Race, David L. Anderson

The Catholic Lawyer

No abstract provided.


Evaluating Beps, Reuven Avi-Yonah, Haiyan Xu 2017 University of Michigan Law School

Evaluating Beps, Reuven Avi-Yonah, Haiyan Xu

Articles

This article evaluates the recently completed Base Erosion and Profit Shifting (BEPS) project of the G20 and OECD and offers some alternatives for reform.


The Negative Capital Account Maze, Walter D. Schwidetzky 2017 University of Baltimore School of Law

The Negative Capital Account Maze, Walter D. Schwidetzky

All Faculty Scholarship

Outside Hubert I and Hubert II, there has been little discussion of negative capital accounts in the tax context and almost no discussion in the nontax context. Nontax law, however, is critically important. This report provides an integrated discussion of the application of tax and nontax law to negative capital accounts.

One of the challenges in writing this report is that it requires a discussion of both the at-risk rules of section 465 and the debt allocation rules of section 752. Complex issues involving sections 465 and 752 and their interaction are worthy of their own articles. Indeed, others have ...


Share-Buyback-Scheme-And-Contemporary-Tax-Treatment-Oluwaseun-Viyon-Ojo.Pdf, Oluwaseun Viyon Ojo 2017 Lagos State University

Share-Buyback-Scheme-And-Contemporary-Tax-Treatment-Oluwaseun-Viyon-Ojo.Pdf, Oluwaseun Viyon Ojo

Oluwaseun Viyon Ojo

This paper briefly examines the concept of share buyback scheme in Nigeria and the extant position of the Nigerian Law as regards the transaction. The present writer essentially places emphasis on an indepth analysis and examination of  the tax implications of the transaction from the perspectives of the tax treatment models in other jurisdictions, particularly the United States, United Kingdom and Canada. From the comparative analysis from the above mentioned jurisdictions, the writer further analyses the present position of the extant Nigerian tax statutes on the possible tax treatment of share buyback in Nigeria. It then finally recommended the possible ...


A Philosophy Toolkit For Tax Lawyers, Bret N. Bogenschneider 2017 The University of Akron

A Philosophy Toolkit For Tax Lawyers, Bret N. Bogenschneider

Akron Law Review

Philosophy functions as a tool for tax lawyers.The various schools of philosophy are akin to a toolkit with different tools suited for differing projects where the more tools the tax lawyer knows how to use, the more effective he or she will be in the practice of tax law. This paper accordingly sets out to provide a systemization of philosophy relevant to tax law in the areas of Moral Philosophy, Legal Philosophy, Law and Economics, Philosophy of Science, Philosophy of Mind, Philosophy of Language, and Critical Legal Studies. A summary is provided of each followed by a discussion of ...


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