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4819 full-text articles. Page 7 of 107.

Summaries For The Fourth Annual Irs/Sjsu Small Business Tax Institute, Padmini Yalamarthi, Fan Wang, Jie Shen, Xuan Hong, Marla Hampton CPA, MBA, Aaron Grey 2016 San Jose State University

Summaries For The Fourth Annual Irs/Sjsu Small Business Tax Institute, Padmini Yalamarthi, Fan Wang, Jie Shen, Xuan Hong, Marla Hampton Cpa, Mba, Aaron Grey

The Contemporary Tax Journal

No abstract provided.


Destination-Based Taxation In The House Republican Blueprint, Wei Cui 2016 Allard School of Law at the University of British Columbia

Destination-Based Taxation In The House Republican Blueprint, Wei Cui

Faculty Publications

The House Republican Task Force on Tax Reform released its Blueprint for tax reform in June 2016, at the center of which is a destination-based cash-flow tax (DBCFT) to replace the current federal income tax on corporations. The House GOP Blueprint represents the first time that the DBCFT has been promoted by political leaders. Initial commentators have stressed the capacity of such a tax (if adopted in the U.S.) to reduce U.S. companies’ incentives for international tax planning and profit shifting, and to allow the U.S. to “leapfrog to the front of the pack” in its tax ...


Pennsylvania School Tax Burden, Gregory J. Collins 2016 University of Pennsylvania

Pennsylvania School Tax Burden, Gregory J. Collins

CPRE Policy Briefs

PA Act 35 was signed into law on June 1, 2016. The act amended the state public school code, including the creation of a school funding formula. In this policy brief, Pennsylvania School Tax Burden, Gregory Collins examines how the new formula directs state basic education funding, how it is allocated to local school districts based on need, its ability to pay, and the local school tax effort. Pennsylvania School Tax Burden examines the claim that differences exist in local school tax burdens across Pennsylvania's 500 districts.


Qualified Residence Interest Deduction: A Win For Unmarried Co-Owners, Christine Manolakas 2016 University of Nevada, Las Vegas -- William S. Boyd School of Law

Qualified Residence Interest Deduction: A Win For Unmarried Co-Owners, Christine Manolakas

Nevada Law Journal

No abstract provided.


The Trojan Horse Of Corporate Integration, Edward D. Kleinbard 2016 University of Southern California

The Trojan Horse Of Corporate Integration, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

The U.S. Senate Finance Committee has invested significant resources, including hearings and staff reports, to make the case for an unusual form of corporate dividend integration – a corporate dividends-paid deduction, combined with a universal shareholder dividend withholding tax collected from the firm. This proposal would not reduce the cash tax outlays of U.S. corporations in respect of distributed or retained earnings. It would not reduce the aggregate tax burdens imposed on most shareholders, and in many plausible circumstances would raise those tax costs. It is a poorly targeted response to design weaknesses in the U.S. international corporate ...


Determining An Individual's Federal Income Tax Liability When The Tax Benefit Rule Applies: A Fifty-Year Checkup Brings A New Prescription For Calculating Gross, Adjusted Gross, And Taxable Incomes, Matthew J. Barrett 2016 Notre Dame Law School

Determining An Individual's Federal Income Tax Liability When The Tax Benefit Rule Applies: A Fifty-Year Checkup Brings A New Prescription For Calculating Gross, Adjusted Gross, And Taxable Incomes, Matthew J. Barrett

Matthew J. Barrett

The tax benefit rule should be described to indicate that it applies to credits and exclusions besides deductions, and deduction recoveries should be reported in the same location as was affected initially. The recovery should not affect gross income, for the purpose of tax equity. The recovery should rather affect either taxable income or adjusted gross income. The IRS and the courts should adopt this new description and principles.


The Psychological Autopsy In Judicial Opinions Under Section 2035, Thomas L. Shaffer 2016 Notre Dame Law School

The Psychological Autopsy In Judicial Opinions Under Section 2035, Thomas L. Shaffer

Thomas L. Shaffer

No abstract provided.


Welfare State Crime In Canada: The Politics Of Tax Evasion In The 1980s, Lorne Sossin 2016 Osgoode Hall Law School of York University

Welfare State Crime In Canada: The Politics Of Tax Evasion In The 1980s, Lorne Sossin

Lorne Sossin

This paper considers the phenomenon of tax evasion in the 1980s in Canada as an outgrowth of a crisis in the welfare state. The lack of social protest over the high incidence of tax evasion among the wealthiest stratum of Canadian individuals and corporations is, on this view, linked to the transformation of politicized citizens into depoliticized clients. Tax evasion, along with legal tax avoidance both proliferated in the 1980s which reflects the convergence of a number of events including the increase in use of tax expenditures, the decreasing emphasis on enforcement in tax administration, the rise of neoconservatism and ...


Northwestern, O'Bannon And The Future: Cultivating A New Era For Taxing Qualified Scholarships, Kathryn Kisska-Schulze, Adam Epstein 2016 Central Michigan University

Northwestern, O'Bannon And The Future: Cultivating A New Era For Taxing Qualified Scholarships, Kathryn Kisska-Schulze, Adam Epstein

Adam Epstein

On March 26, 2014, the National Labor Relations Board (NLRB) ruled that Northwestern University’s scholarship football players were employees of the institution and could unionize and bargain collectively. From a federal income tax perspective, the significance of the NLRB decision - at that time - was that it could redefine the principle that select student-athletes are no longer unpaid amateurs receiving qualified scholarships, but instead are employees of their institutions earning scholarship funds in exchange for services rendered as college athletes. Accordingly, a crucial question arising from the NLRB holding was whether the Internal Revenue Service (IRS) could logically continue to ...


All Is Whale That Ends Whale? The Deficiencies In National Protection For Orca Whales In Captivity, Hillary T. Wise 2016 The University of Akron

All Is Whale That Ends Whale? The Deficiencies In National Protection For Orca Whales In Captivity, Hillary T. Wise

Akron Law Review

With the severity of our Earth’s climate change crisis, this article endeavors to underline the critical need for environmental reformation. It is no secret that orca whales epitomize miraculous intelligence, gentility, and strength. As overwhelming as this crisis might be, there are very concrete steps that our legal system can take to begin protecting and making a difference for our whales and our Earth. It is my hope that this article can shed some light on what is at stake for these animals, and how we might move forward toward a sustainable, safe future for them.


Getting Back To The "Grassroots" Of Tax Administration: Because "We The People" Long For A Gathering Of American Eagles To Restore Trust In The Internal Revenue Service With A Rebuild Irs Initiative, Frank Wolpe 2016 The University of Akron

Getting Back To The "Grassroots" Of Tax Administration: Because "We The People" Long For A Gathering Of American Eagles To Restore Trust In The Internal Revenue Service With A Rebuild Irs Initiative, Frank Wolpe

Akron Law Review

Like America, our Internal Revenue Service is a work in progress. Yet, for best results, it’s better to avoid thinking too much about what it is or is not! Instead, let’s think more about what the IRS ought to be! This Article thusly offers a realistic path forward with new choices for a local presence, which once again makes it taxpayer/customer-centric. For more effective tax administration, it also offers a return to something that inexcusably went missing in 1998: senior-executive “on-site oversight” of field operations.

If today’s Internal Revenue Service can be fairly described as an ...


The Quagmire Of Mortgage Short Sale Transactions Under Current Homeownership Tax Policy In A Time Of Crisis, Tracie R. Porter 2016 The University of Akron

The Quagmire Of Mortgage Short Sale Transactions Under Current Homeownership Tax Policy In A Time Of Crisis, Tracie R. Porter

Akron Law Review

The 2007 financial crisis continues to loom over homeowners who own underwater properties. What owning underwater property means for homeowners is that the home’s current market value is less than the mortgage balance, making it impossible to sell or refinance the home without the lender’s approval. The quagmire of financial indebtedness created by current tax laws and policy related to Mortgage Short Sale Transactions, or MSSTs, for homeowners creates an onerous tax liability on taxpayers selling underwater properties. The government and lenders, through various programs implemented to help distressed homeowners with underwater properties, created a belief among homeowners ...


Northwestern, O'Bannon And The Future: Cultivating A New Era For Taxing Qualified Scholarships, Kathryn Kisska-Schulze, Adam Epstein 2016 The University of Akron

Northwestern, O'Bannon And The Future: Cultivating A New Era For Taxing Qualified Scholarships, Kathryn Kisska-Schulze, Adam Epstein

Akron Law Review

On March 26, 2014, the National Labor Relations Board (NLRB) ruled that Northwestern University’s scholarship football players were employees of the institution and could unionize and bargain collectively. From a federal income tax perspective, the significance of the NLRB decision—at that time—was that it could redefine the principle that select student-athletes are no longer unpaid amateurs receiving qualified scholarships, but instead are employees of their institutions, earning scholarship funds in exchange for services rendered as college athletes. Accordingly, a crucial question arising from the NLRB holding was whether the Internal Revenue Service could logically continue to treat ...


Treasury Should Exclude Income From Discharge Of Student Loans, John R. Brooks 2016 Georgetown University Law Center

Treasury Should Exclude Income From Discharge Of Student Loans, John R. Brooks

Georgetown Law Faculty Publications and Other Works

There are several ways that a student loan borrower can have a federal student loan discharged. In some cases, that cancellation of student debt creates taxable income, but in others it does not. This Article argues that taxing cancellation of student debt undermines the purposes of loan discharge and income-driven repayment programs like IBR and PAYE. This Article further argues that, if Congress does not act to provide a clear exclusion, Treasury has sufficient statutory and common law authority to exclude that income, and that it should do so.


'The Better Part Of Valour Is Discretion': Should The Irs Change Or Surrender Its Oversight Of Tax-Exempt Organizations?, Lloyd Hitoshi Mayer 2016 Notre Dame Law School

'The Better Part Of Valour Is Discretion': Should The Irs Change Or Surrender Its Oversight Of Tax-Exempt Organizations?, Lloyd Hitoshi Mayer

Lloyd Hitoshi Mayer

Recent events have highlighted the difficulties the Internal Revenue Service faces when attempting to ensure that purportedly tax-exempt organizations in fact qualify for that status. The problems in this area go much deeper than a group of IRS employees subjecting certain organizations to greater scrutiny based on their political leanings, however. For decades members of the public, the media, the academy, and Congress have criticized the limited ability of the IRS to ensure that organizations claiming exemption from federal income tax in fact deserve that categorization. Yet examples of IRS failings in this area continue to arise with depressing frequency ...


General Electric's Tax Liability: The Case For Corporate Tax Reform, Willis L. Krumholz 2016 University of St. Thomas, Minnesota

General Electric's Tax Liability: The Case For Corporate Tax Reform, Willis L. Krumholz

University of St. Thomas Journal of Law and Public Policy

No abstract provided.


Increasing Charitable Contributions Through The Use Of Trusts, Philip P. Martin, Jr., Joseph A. Sinclitico 2016 St. John's University School of Law

Increasing Charitable Contributions Through The Use Of Trusts, Philip P. Martin, Jr., Joseph A. Sinclitico

The Catholic Lawyer

No abstract provided.


Registered Savings Plans And The Making Of Middle Class Canada: Toward A Performative Theory Of Tax Policy, Lisa Philipps 2016 Osgoode Hall Law School of York University

Registered Savings Plans And The Making Of Middle Class Canada: Toward A Performative Theory Of Tax Policy, Lisa Philipps

Lisa Philipps

Politicians across Canada’s political spectrum strive to position themselves as defenders of the middle class, and tax policy is a prime vehicle for making this pitch. Any tax reform proposal can be examined critically to evaluate its likely distributional impacts and how well these map onto specific definitions of the middle class. This article attempts, however, a different project. Drawing on the ideas of Judith Butler, it analyzes instead how tax policy produces middle-class identity through the very process of claiming to advance middle-class interests. The case study for this purpose is the rise of tax incentives for saving ...


Motion For Leave To File Brief And Brief Of The National Taxpayers Union, The Nevada Manufacturers Association, The Howard Jarvis Taxpayers Foundation, Americans For Limited Government, Americans For Tax Reform, The Club For Growth, Nevada Corporate Headquarters, Inc., The Nevada Motor Transport Association, The Retail Association Of Nevada, And The Reno-Sparks Chamber Of Commerce, As Amici Curiae In Support Of Petitioners, Paul E. Salamanca 2016 University of Kentucky College of Law

Motion For Leave To File Brief And Brief Of The National Taxpayers Union, The Nevada Manufacturers Association, The Howard Jarvis Taxpayers Foundation, Americans For Limited Government, Americans For Tax Reform, The Club For Growth, Nevada Corporate Headquarters, Inc., The Nevada Motor Transport Association, The Retail Association Of Nevada, And The Reno-Sparks Chamber Of Commerce, As Amici Curiae In Support Of Petitioners, Paul E. Salamanca

Paul E. Salamanca

No abstract provided.


The Administration Of Canada’S Transfer Pricing Rules: Issues And Recommendations, Jinyan Li, Pierre Barsalou, John Oatway, François Vincent 2016 Osgoode Hall Law School of York University

The Administration Of Canada’S Transfer Pricing Rules: Issues And Recommendations, Jinyan Li, Pierre Barsalou, John Oatway, François Vincent

Jinyan Li

No abstract provided.


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