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4692 full-text articles. Page 6 of 102.

Comparison And Assessment Of The Tax Treatment Of Foreign Source Income In Canada, Australia, France, Germany And The United States, Jinyan Li, Brian Arnold, Nolan Sharkey 2016 Osgoode Hall Law School of York University

Comparison And Assessment Of The Tax Treatment Of Foreign Source Income In Canada, Australia, France, Germany And The United States, Jinyan Li, Brian Arnold, Nolan Sharkey

Jinyan Li

No abstract provided.


Searching For Our Fiscal Soul, Edward D. Kleinbard 2016 University of Southern California

Searching For Our Fiscal Soul, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

This is an extended version of a presentation made at TEDx Livermore 2016, the theme of which was the Economics of Empathy. Searching for Our Fiscal Soul argues that democracy is an exercise in empathy towards fellow citizens we do not know, and, if we did, might not like. We express that empathy through government spending, because that is how we actualize values that are important enough that we are willing to pay for them. This is our fiscal soul in action. Whether measured against the values we all routinely recite, or against the social environments achieved by peer countries ...


It's Tax Not Trade (Stupid), Edward J. McCaffery 2016 University of Southern California;California Institute of Tecnology

It's Tax Not Trade (Stupid), Edward J. Mccaffery

University of Southern California Legal Studies Working Paper Series

Globalization, trade and other free market policies increase wealth. But the gains from trade are not being evenly spread among all citizens. People and politicians rage against foreigners. But it is the United States tax system, not trade, that ought to change, and wealthy Americans, not workers world-wide, who should be sharing the wealth. A nd it is the form of tax, not just its rate structure, that must reform, so that capital at last bears a meaningful share of the burden.


Quis Custodiet: Disestablishment And Standing To Sue, Thomas J. O'Toole 2016 St. John's University School of Law

Quis Custodiet: Disestablishment And Standing To Sue, Thomas J. O'Toole

The Catholic Lawyer

No abstract provided.


The Constitutional Nature Of The United States Tax Court, Brant J. Hellwig 2016 Washington and Lee University School of Law

The Constitutional Nature Of The United States Tax Court, Brant J. Hellwig

Brant J. Hellwig

None available.


Real Estate Investment Trusts In Canada, Samita Pachai 2016 The University of Western Ontario

Real Estate Investment Trusts In Canada, Samita Pachai

Electronic Thesis and Dissertation Repository

The Canadian real estate investment trust (REIT) industry began in the early 1990s and, over the past twenty years, the legislative landscape governing REITs has changed dramatically. This dissertation examines how REIT legislation has progressed in Canada and the effects it has had on the industry as a whole. After examining the basic characteristics of a REIT, an overview of the legislative evolution is presented. This thesis argues that recent legislation has been successful in allowing REITs to flourish, with 48 public equity REITs now trading in Canada comprising a market capitalization of over CAD 50 billion. A thorough examination ...


The U.S. Response To Oecd-Beps And The Eu State Aid Cases, Daniel Shaviro 2016 NYU School of Law

The U.S. Response To Oecd-Beps And The Eu State Aid Cases, Daniel Shaviro

New York University Law and Economics Working Papers

This is the slightly expanded text of a talk that the author gave on June 1, 2016, at a conference in Amsterdam that was cosponsored by NYU Law School and the Amsterdam Centre for Tax Law. The conference concerned anti-BEPS implementation in the EU, and the talk concerned the U.S. response to such efforts.


10 Observations Concerning International Tax Policy, Daniel Shaviro 2016 NYU School of Law

10 Observations Concerning International Tax Policy, Daniel Shaviro

New York University Law and Economics Working Papers

This is a slightly revised version of a lunch talk that the author gave at the National Tax Association’s 46th Annual Spring Symposium on May 12. It addresses, among other topics, why there is so little consensus regarding international tax policy, and what lessons we learn from the recent wave of inversions by U.S. companies.


Perspectives - Susanna Fodor Of Scarola Malone Zubatov, James Hagy, Alicia Langone 2016 New York Law School

Perspectives - Susanna Fodor Of Scarola Malone Zubatov, James Hagy, Alicia Langone

Rooftops Project

In a recent visit with the Rooftops Project's Alicia Langone and Professor James Hagy, construction lawyer Susanna Fodor offers views on the tenant improvement process when a not-for-profit organization selects space to lease and on routine repair and renovation projects for properties a not-for-profit may own.


Perspectives - Marty Festenstein Of Nelson, James Hagy, Jennessy Angie Rivera 2016 New York Law School

Perspectives - Marty Festenstein Of Nelson, James Hagy, Jennessy Angie Rivera

Rooftops Project

Interior Design Professional Marty Festenstein shares insights on the design process for tenant spaces with Professor James Hagy and Rooftops Project team member Jennsessey Rivera.


Perspectives - Emmy Award-Winning Producer And Director Thomas Kaufman, James Hagy, Colin Pearce 2016 New York Law School

Perspectives - Emmy Award-Winning Producer And Director Thomas Kaufman, James Hagy, Colin Pearce

Rooftops Project

What makes an effective message when asking for donations to a capital project using video and streaming media? Professor James Hagy and Rooftops Team member Colin Pearce asked Emmy Award-winning producer and director Tom Kaufman after screening his remarkable two-minute video for the Playtime Project, the goal of which was to fund construction of a children’s playground for a large homeless shelter in a converted, former general hospital in the District of Columbia.


The Luxembourg Effect: Patent Boxes And The Limits Of International Cooperation, Lilian V. Faulhaber 2016 Georgetown University Law Center

The Luxembourg Effect: Patent Boxes And The Limits Of International Cooperation, Lilian V. Faulhaber

Georgetown Law Faculty Publications and Other Works

This article uses patent boxes, which reduce taxes on income from patents and other IP assets, to illustrate the fact that the jurisprudence of the European Court of Justice has a longer reach than has previously been recognized. This article argues that, along with having effects within the European Union, the ECJ’s decisions can also have effects on countries outside of the EU. In the direct tax context, the ECJ’s jurisprudence has hampered the ability of both EU and non-EU countries to police international tax avoidance.

In 2015, the Organisation for Economic Co-operation and Development (OECD) proposed restrictions ...


Taxation As Insurance, John R. Brooks 2016 Georgetown University Law Center

Taxation As Insurance, John R. Brooks

Georgetown Law Faculty Publications and Other Works

A central yet often overlooked aspect of an income tax is that it acts as insurance against the risk of low income. Because a person’s payments to government are a function of income, he can be assured that in a time of low income, his tax payments will decrease and transfers will increase, while the standard benefits of governments continue to flow. Because everyone, no matter how successful, faces some risk of lost income, that assurance provides us an insurance benefit, even if our income never actually drops.


International Tax Implications Of The Organisation For Economic Co-Operation And Development Proposal To Neutralize Hybrid Mismatch Arrangements, Dean Harris 2016 The Catholic University of America, Columbus School of Law

International Tax Implications Of The Organisation For Economic Co-Operation And Development Proposal To Neutralize Hybrid Mismatch Arrangements, Dean Harris

Catholic University Law Review

The Organisation for Economic Co-operation and Development (OECD) has developed a sixteen part plan titled Base Erosion and Profit Shifting (BEPS). This comment focuses on the second part of that plan; Neutralizing Hybrid Mismatch Arrangements. Mismatches have become a useful tool for corporations to achieve double non-taxation in various jurisdictions. The comment begins by laying the groundwork of what a hybrid mismatch arrangement is and the current problems and complications with them in international tax. Next, this comment addresses various jurisdictional approaches to mismatches, including: Ireland, The United Kingdom, The United States, and Denmark. The paper moves forward onto a ...


Give Taxpayers A Break: Putting The Reliance Element Back Into The Reasonable Reliance And Good Faith Defense, Ronald Z. Domsky 2016 Selected Works

Give Taxpayers A Break: Putting The Reliance Element Back Into The Reasonable Reliance And Good Faith Defense, Ronald Z. Domsky

Ronald Z. Domsky

No abstract provided.


The Uneasy Case For The Retirement Of Douglas Kahn, Jeffrey H. Kahn 2016 Florida State University

The Uneasy Case For The Retirement Of Douglas Kahn, Jeffrey H. Kahn

Michigan Business & Entrepreneurial Law Review

In the fall semester of 1964, a young Douglas Kahn joined the faculty of the University of Michigan Law School. During the spring semester of 2016, he will teach his final course as a full-time faculty member. For the interim fifty two years, he has been a fixture of the Michigan law school community. As a tax professor, former student, and his son, I am pleased and honored to write this introduction for an edition of the Michigan Business & Entrepreneurial Law Review honoring Professor Kahn’s tenure at the University of Michigan.


A Grateful Testimonial To Doug Kahn, Terrence G. Perris 2016 University of Michigan Law School

A Grateful Testimonial To Doug Kahn, Terrence G. Perris

Michigan Business & Entrepreneurial Law Review

It is difficult for me to accept the reality that Doug Kahn is about to retire after a triumphant fifty-two year tenure as a professor at the University of Michigan Law School. For much of the nearly forty-seven years of my association with the Law School, first as a student and then as an alumnus, Doug has practically symbolized the Law School for me, as he went from being a revered teacher, to a valued mentor, to a dear friend, to a colleague and co-author, and, dare I say, to virtually a member of the family. But I am only ...


Where Does One Begin To Describe A Professor Who Literally Changed Your Life?, Kelli Turner 2016 University of Michigan Law School

Where Does One Begin To Describe A Professor Who Literally Changed Your Life?, Kelli Turner

Michigan Business & Entrepreneurial Law Review

A bit of background to set the stage, if you’ll indulge me. Growing up in West Bloomfield, Michigan, I was never overly ambitious, nor did I have any lofty academic goals. In particular, I never had any desire to go to law school or, for that matter, to become a lawyer. I come from a family of trial attorneys and it never interested me much. I was a numbers person and didn’t enjoy a lot of deep reading and essay writing (somewhat ironic as I’m writing this for a law journal). But when I started in public ...


Doug Kahn: The Pied Piper Of Tax Law, Barrie Lawson Loeks, Burt P. Rosen 2016 University of Michigan Law School

Doug Kahn: The Pied Piper Of Tax Law, Barrie Lawson Loeks, Burt P. Rosen

Michigan Business & Entrepreneurial Law Review

Doug Kahn’s love of tax law appears to be contagious. His wife was a tax lawyer, his son is now a tax law professor, and even his daughter in law is a tax lawyer. Doug may have caught the “tax disease” from his elder brother, who was also a leading tax lawyer. In politics, we have the Kennedys, the Bushes, and the Clintons; in the world of tax law, we have the Kahn family dynasty. One can only assume that the discussions around the family Thanksgiving table sliced and diced tax regulations and policies right along with the turkey ...


A Note, Robert T. Pelinka Jr. 2016 University of Michigan Law School

A Note, Robert T. Pelinka Jr.

Michigan Business & Entrepreneurial Law Review

I find it quite meaningful that heartwarming reflections about Douglas Kahn come very naturally to me. Perhaps that, in and of itself, says something about this incredible man. For context, my time in physical proximity to Professor Kahn came during my years as a student-athlete at the University of Michigan, where I graduated from the Ross School of Business, and the Law School. I was also a member of The Michigan Wolverines Basketball Team, where I participated in three NCAA Final Fours, and earned an NCAA Championship Title. I mention these things, not to tout my own accomplishments, but rather ...


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