¿Transparencia En El Endeudamiento Público?, 2012 UDLAP, BUAP, UPAEP, UVM, ANAHUAC, LIBRE DE DERECHO, IBERO-PUEBLA
¿Transparencia En El Endeudamiento Público?, Norma E. Pimentel
Norma E Pimentel
No abstract provided.
Giving Useful Tax Planning Advice, 2012 UC Hastings College of the Law
Giving Useful Tax Planning Advice, Heather M. Field
Faculty Scholarship
No abstract provided.
Quoted In Law360 On Ex-Ceo Pay, 2012 Texas A&M University School of Law
Quoted In Law360 On Ex-Ceo Pay, Robert D. Probasco
Robert Probasco
No abstract provided.
Front Matter, 2012 Maurice A. Deane School of Law at Hofstra University
Major Reforms Of The Property Restatement And The Uniform Probate Code: Reformation, Harmless Error, And Nonprobate Transfers, 2012 Maurice A. Deane School of Law at Hofstra University
Major Reforms Of The Property Restatement And The Uniform Probate Code: Reformation, Harmless Error, And Nonprobate Transfers, John H. Langbein
ACTEC Law Journal
In late 2011, the American Law Institute published the third and final volume of the Restatement (Third) of Property: Wills and Other Donative Transfers. In March 2012, the Restatement's two reporters, Professors Lawerence W. Waggoner and John H. Langbein, presented the Joseph Trachtman Memorial Lecture at the annual meeting of the American College of Trust and Estate Counsel in Miami Beach. Introducing the two lecturers, ACTEC President Mary Radford described them as "two icons in our field, [who] have had a hand in every major development in trust and estate law that has occurred over the past three decades..." In …
What's In The Third And Final Volume Of The New Restatement Of Property That Estate Planners Should Know About, 2012 Maurice A. Deane School of Law at Hofstra University
What's In The Third And Final Volume Of The New Restatement Of Property That Estate Planners Should Know About, Lawrence W. Waggoner
ACTEC Law Journal
No abstract provided.
The Anti-Injunction Act, Congressional Inactivity, And Pre-Enforcement Challenges To § 5000a Of The Tax Code, 2012 University of Richmond School of Law
The Anti-Injunction Act, Congressional Inactivity, And Pre-Enforcement Challenges To § 5000a Of The Tax Code, Kevin C. Walsh
University of Richmond Law Review
No abstract provided.
Refund Fraud? Real-Time Solution!, 2012 Boston University School of Law
Refund Fraud? Real-Time Solution!, Richard Thompson Ainsworth
Faculty Scholarship
When seven million dependents vanished from the tax rolls in 1986 the IRS recovered three billion dollars in revenue. A simple enforcement measure was applied. Taxpayers were required to list the social security number (SSN) for any dependent they claimed on their tax return. Costing next to nothing to implement, the benefits of this enforcement action continue to this day.
A similar enforcement measure could be employed against refund fraud. Even though the solution is not as simple as that adopted in 1986, it is similar. The effort is worth making. The revenue loss is much larger. As before, the …
Comments On Proposed Amendments To The Rules Of The United States Tax Court, 2012 Texas A&M University School of Law
Comments On Proposed Amendments To The Rules Of The United States Tax Court, Robert D. Probasco
Robert Probasco
Giving Strategies In The New Tax Climate, 2012 Texas A&M University School of Law
Giving Strategies In The New Tax Climate, Terri Helge
Terri L. Helge
No abstract provided.
Tax & Legislative Update: Recent Developments In Charitable Giving, 2012 Texas A&M University School of Law
Tax & Legislative Update: Recent Developments In Charitable Giving, Terri Helge
Terri L. Helge
No abstract provided.
Aspectos Generales Dela Publicidad En México. "La Publicidad De Productos, Servicios, Y Actividades Reguladas Por La Ley General De Salud", 2012 ITESM Campus Puebla
Aspectos Generales Dela Publicidad En México. "La Publicidad De Productos, Servicios, Y Actividades Reguladas Por La Ley General De Salud", Bruno L. Costantini García
Bruno L. Costantini García
Introducción a las generalidades de la regulación en materia de publicidad de insumos para el consumo humano (salud) en México.
Inconstitucionalidad Del Cobro Del Impuesto Sobre La Renta Sobre Jubilaciones, Pensiones Y Haberes De Retiro, 2012 Ilustre y Nacional Colegio de Abigados de México, A.C.
Inconstitucionalidad Del Cobro Del Impuesto Sobre La Renta Sobre Jubilaciones, Pensiones Y Haberes De Retiro, Guillermo Castorena
Guillermo Castorena
Argumentos de inconstitucionalidad del precepto. - La LISR no grava el ingreso por pensiones y por ende artículo el 109 fracción III es inconstitucional al no existir el objeto del gravamen. - Violación al artículo 5º de la Constitución Política de los Estados Unidos Mexicanos (CPEUM) pues al ser las pensiones, jubilaciones y haberes de retiro producto del trabajo, la retención realizada con fundamento en el artículo 109 fracción III, constituye una doble tributación. - Violación a los artículos 123 y 127 de la CPEUM, que señalan que el salario será gravable, pero no así la pensión. - Violación a …
U.S. Treaty Anti-Avoidance Rules: An Overview And Assessment, 2012 University of Michigan Law School
U.S. Treaty Anti-Avoidance Rules: An Overview And Assessment, Reuven S. Avi-Yonah, Oz Halabi
Law & Economics Working Papers
In this article, the authors provide a summary of the anti-avoidance rules in the United States that relate to bilateral tax treaties. Specifically, they focus on treaty-based anti-avoidance rules and discuss whether or not a General Anti-Avoidance Rule would be appropriate in this context.
U.S. International Tax Reform: What Form Should It Take?, 2012 University of Washington School of Law
U.S. International Tax Reform: What Form Should It Take?, Jeffrey M. Kadet
Articles
This article focuses solely on the big picture issue of whether international tax reform should take the form of a territorial system or an alternative full inclusion system. Of course, it is also necessary to compare these possible new systems with the current hybrid deferral system that has been in place for many years.
With little if any explanation of how it might be better for our nation and society as a whole, many persons and commentators whose companies or clients stand to benefit have called for a territorial system. Such persons have included CEOs, members of the professional tax …
Boomer-Ang Eldercare: Deductible Claim?, 2012 University of Baltimore School of Law
Boomer-Ang Eldercare: Deductible Claim?, Wendy G. Gerzog
All Faculty Scholarship
In this article, Gerzog discusses Estate of Olivo, in which the Tax Court determined the deductibility under section 2053 of a claim against the decedent’s estate for eldercare services provided by a family member.
The Curious Case Of Tribunalization, 2012 O.P. Jindal Global University
The Curious Case Of Tribunalization, Khagesh Gautam Prof.
Khagesh Gautam
No abstract provided.
Territorial W&M Discussion Draft: Change Required, 2012 University of Washington School of Law
Territorial W&M Discussion Draft: Change Required, Jeffrey M. Kadet
Articles
The House Ways & Means Committee Discussion Draft proposes a territorial taxation system for the United States. This article published in Tax Notes on 23 January 2012 was taken from the author's comments on the Discussion Draft as submitted to the Committee in conjunction with a hearing held on 17 November 2011. See full comments at http://ssrn.com/abstract=1997482. The full comments include many additional issues not covered in this article.
The Discussion Draft importantly includes a dividend-received deduction of 95% instead of 100% as a mechanism to disallow expenses that are attributable to exempt foreign earnings. This mechanism causes the receipt …
Transfer Pricing: Data Dumps And Comparability - Us, Uk, Canadian, And Australian Case Studies, 2012 Boston University School of Law
Transfer Pricing: Data Dumps And Comparability - Us, Uk, Canadian, And Australian Case Studies, Richard Thompson Ainsworth, Andrew Shact
Faculty Scholarship
Comparability is the heart of transfer pricing. The OECD, U.K., Canadian, Australian, and U.S. transfer pricing rules all echo one another on how critically important the comparability analysis is. Performing this analysis and proving comparability, however, is a demanding exercise.
What makes proving comparability so difficult is that the analysis is two sided. Both controlled and uncontrolled transactions must be thoroughly analyzed. Just as much effort needs to be applied to determine the functions, contract terms, risks and the economic conditions for the unrelated party comparables as is spent on analyzing the related parties (taxpayers).
But there is more to …
“Early-Bird Special” Indeed!: Why The Tax Anti-Injunction Act Permits The Present Challenges To The Minimum Coverage Provision, 2012 Cornell Law School
“Early-Bird Special” Indeed!: Why The Tax Anti-Injunction Act Permits The Present Challenges To The Minimum Coverage Provision, Michael C. Dorf, Neil S. Siegel
Cornell Law Faculty Publications
In view of the billions of dollars and enormous effort that might otherwise be wasted, the public interest will be best served if the Supreme Court of the United States reaches the merits of the present challenges to the Patient Protection and Affordable Care Act (ACA) during its October 2011 Term. Potentially standing in the way, however, is the federal Tax Anti-Injunction Act (TAIA), which bars any “suit for the purpose of restraining the assessment or collection of any tax.” The dispute to date has mostly turned on the fraught and complex question of whether the ACA’s exaction for being …