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A Whole New World: Income Tax Considerations Of The Bitcoin Economy, Benjamin W. Akins JD, LLM, Jennifer L. Chapman JD, CPA, Jason M. Gordon JD, MBA 2015 SelectedWorks

A Whole New World: Income Tax Considerations Of The Bitcoin Economy, Benjamin W. Akins Jd, Llm, Jennifer L. Chapman Jd, Cpa, Jason M. Gordon Jd, Mba

Benjamin W. Akins

Bitcoin is a virtual, cryptocurrency growing rapidly in influence throughout the world. Numerous characteristics associated with the bitcoin system, including low transaction costs and greater user privacy, make it appealing as a medium of electronic payment. The number of users of bitcoin, including merchants accepting the currency as a form of payment, has grown considerably in recent years. Estimates indicate that there are more than 60,000 active bitcoin users as of September 2012, with nearly 11 million bitcoins in existence. According to the latest estimates, bitcoin market capitalization is roughly $9 billion. The growth of bitcoin as an accepted ...


Taxpayers’ Lack Of Standing In International Tax Dispute Resolutions: An Analysis Based On The Hybrid Norms Of International Taxation, Limor Riza 2014 Pace University

Taxpayers’ Lack Of Standing In International Tax Dispute Resolutions: An Analysis Based On The Hybrid Norms Of International Taxation, Limor Riza

Pace Law Review

This paper examines whether a taxpayer should have “standing” in international dispute resolutions. To answer this question the primary task is to identify the nature of international taxation. In other words, this paper discusses how to classify the field of international taxation. Is it part of public international law, private international law (i.e., conflict of laws), national (domestic) law, or is it a hybrid field that requires specific attention? Making this distinction is vital for resolving disputes when a taxpayer is taxed twice for cross-border transactions in cases where the double tax convention is unclear and both contracting states ...


Irs Tax Relief - Tips For Taxpayers - Tax Relief Programmes, Lissa Coffey NYU School of Law 2014 SelectedWorks

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 Installment Agreement) is established, ...★★★★★ Get Tax Help ...


Speak Up: Issue Advocacy In Increasingly Politicized Times, Sally Wagenmaker 2014 Pepperdine University

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 2014 Pepperdine University

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 North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum 2014 University of Georgia School of Law

The North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum

Georgia Journal of International & Comparative Law

No abstract provided.


Court Of Appeals Of New York, Harner V. County Of Tioga, Gerald C. Waters Jr. 2014 Touro College Jacob D. Fuchsberg Law Center

Court Of Appeals Of New York, Harner V. County Of Tioga, Gerald C. Waters Jr.

Touro Law Review

No abstract provided.


Tax Debt Help – Settlement & Negotiation, Lissa Coffey 2014 SelectedWorks

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


Piketty In America: A Tale Of Two Literatures, Joseph Bankman, Daniel Shaviro 2014 NELLCO

Piketty In America: A Tale Of Two Literatures, Joseph Bankman, Daniel Shaviro

New York University Law and Economics Working Papers

Thomas Piketty’s widely-noted and bestselling book, Capital in the Twenty-First Century, does much to advance our empirical understanding of rising high-end wealth concentration, which is one of the central issues of our time. But its theoretical approach and policy recommendations differ sharply from those that have been prevalent in recent decades in the Anglo-American academic tax policy literature. We adjudicate this “confrontation” (insofar as it is one), and find that each approach in some respects both undermines and enriches the other. We find that the optimal tax response to wealth concentration is significantly more complicated than Piketty’s analysis ...


Profits V. Purpose: Hybrid Companies And The Charitable Dollar, Jill R. Horwitz, Rachel Culley 2014 University of Michigan Law School

Profits V. Purpose: Hybrid Companies And The Charitable Dollar, Jill R. Horwitz, Rachel Culley

Law & Economics Working Papers

Social entrepreneurship -- a catch-all term meaning harnessing business practices for social good -- has attracted people who want to “do well while doing good” for decades. Advocates of the idea have succeeded in blurring the boundaries among legal ownership types and inspired nonprofit/for-profit joint ventures, public-private partnerships, and the widespread privatization of traditional government functions and activities. The most recent manifestation of this trend is the creation of hybrid non-profit/for-profit firms. In the United States, the Low-Profit Limited Liability Company (L3C) is growing, and there are similar firms in the United Kingdom and Canada. In this paper we address ...


Reconsidering Corporate Tax Privacy, Joshua D. Blank 2014 NELLCO

Reconsidering Corporate Tax Privacy, Joshua D. Blank

New York University Law and Economics Working Papers

For over a century, politicians, government officials and scholars in the United States have debated whether corporate tax returns, which are currently subject to broad tax privacy protections, should be publicly accessible. The ongoing global discussion of base erosion and profit shifting by multinational corporations has generated calls for greater tax transparency. Throughout this debate, participants have focused exclusively on the potential reactions of a corporation’s managers, shareholders and consumers to a corporation’s disclosure of its own tax return information. There is, however, another perspective: how would the ability of a corporation’s stakeholders and agents to observe ...


Modernizing The Revenue Rule: The Enforcement Of Foreign Tax Judgments, Barbara A. Silver 2014 University of Georgia School of Law

Modernizing The Revenue Rule: The Enforcement Of Foreign Tax Judgments, Barbara A. Silver

Georgia Journal of International & Comparative Law

No abstract provided.


The Rescission Doctrine: Everything Old Is New Again, Allen Sparkman 2014 SelectedWorks

The Rescission Doctrine: Everything Old Is New Again, Allen Sparkman

Allen Sparkman

This paper considers rescissions--attempts by parties to undo a transaction and have that undoing respected for federal tax purposes. Some commentators have questioned the legal basis for the rescission doctrine as applied by the Internal Revenue Service, and others have argued for expansion or restriction of the doctrine. This paper traces the development of the rescission doctrine, examines a critical article that argues that there is no legal precedent that truly supports the rescission doctrine as it is currently applied by the Internal Revenue Service, considers whether there exists sufficient legal authority for the doctrine as applied by the Internal ...


The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson 2014 SelectedWorks

The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson

John Ferguson

No abstract provided.


Gatt/Wto Rules For Border Tax Adjustment And The Proposed European Directive Introducing A Tax On Carbon Dioxide Emissions And Energy, Christian Pitschas 2014 University of Georgia School of Law

Gatt/Wto Rules For Border Tax Adjustment And The Proposed European Directive Introducing A Tax On Carbon Dioxide Emissions And Energy, Christian Pitschas

Georgia Journal of International & Comparative Law

No abstract provided.


Organizations, Reorganizations, Amalgamations, Divisions And Dissolutions: Cross-Border Assets, Double Taxation And Potential Relief Under The U.S.-Canada Tax Treaty, Catherine A. Brown, Christine Manolakas 2014 University of Georgia School of Law

Organizations, Reorganizations, Amalgamations, Divisions And Dissolutions: Cross-Border Assets, Double Taxation And Potential Relief Under The U.S.-Canada Tax Treaty, Catherine A. Brown, Christine Manolakas

Georgia Journal of International & Comparative Law

No abstract provided.


Reorganizaciones Empresariales, Carlos Molina Sandoval 2014 SelectedWorks

Reorganizaciones Empresariales, Carlos Molina Sandoval

Carlos Molina Sandoval

La base de la reorganización es la configuración de hechos imponibles que puedan generar una ganancia sujeta a la LIG. En general, el criterio tributario grava las ganancias desarrolladas por existencia visible cuando sean periódicas e implique permanencia en la fuente o, aun cuando no exista periodicidad o permanencia en la fuente o, en caso de ciertos contribuyentes —sociedades o personas físicas incluidas en el art. 69, LIG—, desarrollen ciertas actividades y las mismas sean complementarias con la explotación comercial.


For Sale--One Level 5 Barbarian For 94,800 Won: The International Effects Of Virtual Property And The Legality Of Its Ownership, Alisa B. Steinberg 2014 University of Georgia School of Law

For Sale--One Level 5 Barbarian For 94,800 Won: The International Effects Of Virtual Property And The Legality Of Its Ownership, Alisa B. Steinberg

Georgia Journal of International & Comparative Law

No abstract provided.


Charitable Giving And Utilitarianism: Problems And Priorities, Miranda Perry Fleischer 2014 Maurer School of Law: Indiana University

Charitable Giving And Utilitarianism: Problems And Priorities, Miranda Perry Fleischer

Indiana Law Journal

Charitable giving is redistributive at heart. It is thus surprising that scholarship on the charitable tax subsidies focuses on the efficient and pluralistic production of public goods while largely ignoring distributive justice concerns. Existing scholarship and current law leave crucial questions unanswered: How should we prioritize among charities? Should subsidized groups be required to help the poor? Are criticisms that charities do too little to help the poor valid? This Article is part of a series that examines how each common theory of distributive justice would answer these questions.

More specifically, this Article explores utilitarianism and the charitable tax subsidies ...


The Medical Device Excise Tax: An Unfair Burden, Elizabeth M. Bolka 2014 Maurer School of Law: Indiana University

The Medical Device Excise Tax: An Unfair Burden, Elizabeth M. Bolka

Indiana Law Journal

No abstract provided.


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