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5,147 full-text articles. Page 3 of 118.

Transparency And Disclosure, Diane Ring 2018 Boston College Law School

Transparency And Disclosure, Diane Ring

Diane M. Ring

Without a stable and adequate tax base, countries lose the financial capacity to provide the infrastructure, social services and development opportunities important to their citizens. In response, the G20 and the Organisation for Economic Co-operation and Development (OECD) organized the project on Base Erosion and Profit Shifting (BEPS). Much of the project has been focused on substantive law — the rules and practices that can allow the tax base of a country to be eroded and profits to be shifted out of the country. But the project recognizes that improved substantive tax rules alone are not sufficient to guarantee the tax ...


Why Section 179(B)(3)(A)'S Business Income Limitation Does Not Apply To Partnerships And S Corporations, David Randall Jenkins Ph.D. 2018 San Jose State University

Why Section 179(B)(3)(A)'S Business Income Limitation Does Not Apply To Partnerships And S Corporations, David Randall Jenkins Ph.D.

The Contemporary Tax Journal

No abstract provided.


Analysis Of S.1352 - 115th Congress (2017-2018) Apprenticeship And Jobs Training Act Of 2017, Veena Hemachandran, Katrina Jodrey, George (Peixuan) Liu, Leigh Ann Moore 2018 San Jose State University

Analysis Of S.1352 - 115th Congress (2017-2018) Apprenticeship And Jobs Training Act Of 2017, Veena Hemachandran, Katrina Jodrey, George (Peixuan) Liu, Leigh Ann Moore

The Contemporary Tax Journal

No abstract provided.


Analysis Of H.R.2802 - 115th Congress (2017-2018) First-Time Homebuyer Savings Account Act Of 2017, Shimiao Gong, Xiaotong Stella Li, Ling Wei, Pingrong Xue 2018 San Jose State University

Analysis Of H.R.2802 - 115th Congress (2017-2018) First-Time Homebuyer Savings Account Act Of 2017, Shimiao Gong, Xiaotong Stella Li, Ling Wei, Pingrong Xue

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal's Interview With Mr. Jim Fuller, Ophelia Ding 2018 San Jose State University

The Contemporary Tax Journal's Interview With Mr. Jim Fuller, Ophelia Ding

The Contemporary Tax Journal

No abstract provided.


Who Truly Benefits From The Mortgage Interest Deduction?, Stephen Wildt MBA 2018 San Jose State University

Who Truly Benefits From The Mortgage Interest Deduction?, Stephen Wildt Mba

The Contemporary Tax Journal

No abstract provided.


Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li 2018 San Jose State University

Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li

The Contemporary Tax Journal

No abstract provided.


Summaries For The 2017 Irs-Sjsu Small Business Tax Institute, Ruchi Chopra CPA, MBA, Ophelia Ding, Surbhi Doshi, Nilesh Lad CPA, Sara Yaqin Sun 2018 San Jose State University

Summaries For The 2017 Irs-Sjsu Small Business Tax Institute, Ruchi Chopra Cpa, Mba, Ophelia Ding, Surbhi Doshi, Nilesh Lad Cpa, Sara Yaqin Sun

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018, 2018 San Jose State University

The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018

The Contemporary Tax Journal

No abstract provided.


Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., CPA, Benjamin George Ph.D. 2018 University of North Texas

Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., Cpa, Benjamin George Ph.D.

The Contemporary Tax Journal

No abstract provided.


Tax Treatment Of High-Tech Start-Up Costs, June (Yun) Hostetter CPA 2018 San Jose State University

Tax Treatment Of High-Tech Start-Up Costs, June (Yun) Hostetter Cpa

The Contemporary Tax Journal

No abstract provided.


R&D Credit Against Payroll Tax Liabilities - The Payroll Tax Credit, Sarah Yaqin Sun 2018 San Jose State University

R&D Credit Against Payroll Tax Liabilities - The Payroll Tax Credit, Sarah Yaqin Sun

The Contemporary Tax Journal

No abstract provided.


Is American Multinational Enterprises’ Honeymoon With The European Union Over?An Analysis Of The European Commission’S Investigations Into American Multinational Enterprises’ Tax Deals With Ireland, Luxembourg And The Netherlands, LUYANG LIU 2018 Loyola Law School, Los Angeles

Is American Multinational Enterprises’ Honeymoon With The European Union Over?An Analysis Of The European Commission’S Investigations Into American Multinational Enterprises’ Tax Deals With Ireland, Luxembourg And The Netherlands, Luyang Liu

Loyola of Los Angeles International and Comparative Law Review

No abstract provided.


The Right Tax At The Right Time, Edward D. Kleinbard 2018 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 ...


Perversion Of The Tax Policymaking Process, Edward D. Kleinbard 2018 University of Southern California

Perversion Of The Tax Policymaking Process, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

The Tax Cuts and Jobs Act can be criticized on many substantive grounds, and for its effect on deficits. But the legislative process also revealed important shortcomings beyond its haste. Traditional tax policy metrics – conventional revenue estimates, dynamic estimates and distributional analyses – yield misleading results in a tax framework that loses over one trillion dollars. The result is that the legislation has even more deleterious welfare implications than these standard metrics suggest.


The Elephant Always Forgets: Us Tax Reform And The Wto, Reuven S. Avi-Yonah, Martin G. Vallespinos 2018 University of Michigan Law School

The Elephant Always Forgets: Us Tax Reform And The Wto, Reuven S. Avi-Yonah, Martin G. Vallespinos

Law & Economics Working Papers

The “Tax Cuts and Jobs Act” (TCJA) enacted on December 22, 2017 includes several provisions that raise WTO compliance issues. At least one such provision, the Foreign-Derived Intangible Income (FDII) rule, is almost certain to draw a challenge in the WTO and is likely to lead to another US loss and resulting sanctions. This outcome would be another addition to the repeated losses suffered by the US for export subsidies from the 1970s to 2004, which led to the imposition of sanctions and the ultimate repeal of the offending regime. The important question for 2018 and beyond is whether the ...


Brief Of Tax Law Professors As Amici Curiae In Support Of Petitioner In Loudoun County, Virginia V. Dulles Duty Free, Llc, Richard Pomp, Daniel Jacob Hemel, Reuven S. Avi-Yonah, Lily L. Batchelder, Samuel D. Brunson, J. Clifton Fleming Jr, David Gamage, Ari Glogower, Jacob Goldin, Hayes R. Holderness, Michael S. Knoll, Zachary Liscow, Ruth Mason, Goldburn Maynard, James R. Repetti, Julie A. Roin, Erin Adele Scharff, Jay A. Soled, Edward A. Zelinsky 2018 University of Connecticut School of Law

Brief Of Tax Law Professors As Amici Curiae In Support Of Petitioner In Loudoun County, Virginia V. Dulles Duty Free, Llc, Richard Pomp, Daniel Jacob Hemel, Reuven S. Avi-Yonah, Lily L. Batchelder, Samuel D. Brunson, J. Clifton Fleming Jr, David Gamage, Ari Glogower, Jacob Goldin, Hayes R. Holderness, Michael S. Knoll, Zachary Liscow, Ruth Mason, Goldburn Maynard, James R. Repetti, Julie A. Roin, Erin Adele Scharff, Jay A. Soled, Edward A. Zelinsky

J. Clifton Fleming, Jr.

For more than seven decades, state and local governments as well as market actors have labored under an export tax regime that is inconsistent, inefficient, and inequitable. The petition for a writ of certiorari in Loudoun County, Virginia, v. Dulles Duty Free, LLC, presents the Supreme Court with a chance to restore rationality to the tax treatment of the export sector. The economic implications are vast: annual exports of goods from the United States exceed $1.4 trillion. The Court’s resolution of this case will determine whether state and local governments can apply their sales and personal property taxes ...


Macroeconomic Modeling Of Tax Policy: A Comparison Of Current Methodologies, Itai Grinberg, Alan J. Auerbach, Thomas A. Barthold, Nicholas Bull, W. Gavin Elkins, Pamela J. Moomau, Rachel Moore, Benjamin Page, Brandon Pecoraro, Kyle Pomerleau 2018 Georgetown University Law Center

Macroeconomic Modeling Of Tax Policy: A Comparison Of Current Methodologies, Itai Grinberg, Alan J. Auerbach, Thomas A. Barthold, Nicholas Bull, W. Gavin Elkins, Pamela J. Moomau, Rachel Moore, Benjamin Page, Brandon Pecoraro, Kyle Pomerleau

Alan J. Auerbach

The macroeconomic effects of tax reform are a subject of significant discussion and controversy. In 2015, the House of Representatives adopted a new “dynamic scoring” rule requiring a point estimate within the budget window of the deficit effect due to the macroeconomic response to certain proposed tax legislation. The revenue estimates provided by the staff of the Joint Committee on Taxation (JCT) for major tax bills often play a critical role in Congressional deliberations and public discussion of those bills. The JCT has long had macroeconomic analytic capability, and in recent years, responding to Congress’ interest in macrodynamic estimates for ...


Cracking Shells: The Panama Papers & Looking To The European Union's Anti-Money Laundering Directive As A Framework For Implementing A Multilateral Agreement To Combat The Harmful Effects Of Shell Companies, Nicholas Vail 2018 Texas A&M University School of Law

Cracking Shells: The Panama Papers & Looking To The European Union's Anti-Money Laundering Directive As A Framework For Implementing A Multilateral Agreement To Combat The Harmful Effects Of Shell Companies, Nicholas Vail

Texas A&M Law Review

In early 2016, the International Consortium of Investigative Journalists released a report detailing thousands of leaked documents demonstrating how a Panamanian law firm had, for years, helped wealthy clients conceal their financial activities through the use of offshore shell companies. The Panama Papers, as the leaked documents came to be known, directed renewed attention at the use of shell companies. Shell companies are used by the world’s wealthy and powerful to lower their taxes, but are also used by tax evaders, criminal organizations, and terrorists. While much of the renewed attention has been directed at offshore tax havens such ...


Beat It: Tax Reform And Tax Treaties, Reuven S. Avi-Yonah 2018 University of Michigan Law School

Beat It: Tax Reform And Tax Treaties, Reuven S. Avi-Yonah

Law & Economics Working Papers

The Tax Cuts and Jobs Act (TCJA) includes several provisions that may be viewed as potential violations of US tax treaties. However, most of those potential violations, such as new IRC section 951A and to a large extent new IRC section 59A, are covered by the Savings Clause (US model article 1(4)). The only remaining question is whether IRC section 59A (the “Base Erosion Anti-Abuse Tax”, or BEAT) violates the non-discrimination provision (article 24), which is exempted from the Savings Clause. The answer is no, because foreign related parties are not comparable to US related parties receiving interest or ...


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