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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 Georgia Gwinnett College

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 ...


Definitions, Religion, And Free Exercise Guarantees, Mark Strasser 2015 Capital University Law School

Definitions, Religion, And Free Exercise Guarantees, Mark Strasser

Mark Strasser

The First Amendment to the United States Constitution protects the free exercise of religion. Non-religious practices do not receive those same protections, which makes the ability to distinguish between religious and non-religious practices important. Regrettably, members of the Court have been unable to agree about how to distinguish the religious from the non-religious—sometimes, the implicit criteria focus on the sincerity of the beliefs, sometimes the strength of the beliefs or the role that they play in an individual’s life, and sometimes the kind of beliefs. In short, the Court has virtually guaranteed an incoherent jurisprudence by sending contradictory ...


The Moonscape Of Tax Equality: Windsor And Beyond, Anthony C. Infanti 2015 Northwestern University School of Law

The Moonscape Of Tax Equality: Windsor And Beyond, Anthony C. Infanti

Northwestern University Law Review

No abstract provided.


Tax-Free Reorganizations: The Evolution And Revolution Of Triangular Mergers, Stephanie Hoffer, Dale A. Oesterle 2015 Northwestern University School of Law

Tax-Free Reorganizations: The Evolution And Revolution Of Triangular Mergers, Stephanie Hoffer, Dale A. Oesterle

Northwestern University Law Review

No abstract provided.


A Corporate Tax For The Next One Hundred Years: A Proposal For A Dynamic, Self-Adjusting Corporate Tax Rate, Adam H. Rosenzweig 2015 Northwestern University School of Law

A Corporate Tax For The Next One Hundred Years: A Proposal For A Dynamic, Self-Adjusting Corporate Tax Rate, Adam H. Rosenzweig

Northwestern University Law Review

No abstract provided.


Does Federal Spending "Coerce" States? Evidence From State Budgets, Brian Galle 2015 Northwestern University School of Law

Does Federal Spending "Coerce" States? Evidence From State Budgets, Brian Galle

Northwestern University Law Review

No abstract provided.


A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie Hunter McMahon 2015 Northwestern University School of Law

A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie Hunter Mcmahon

Northwestern University Law Review

No abstract provided.


Brackets: A Historical Perspective, Tracey M. Roberts 2015 Northwestern University School of Law

Brackets: A Historical Perspective, Tracey M. Roberts

Northwestern University Law Review

No abstract provided.


Schedularity In U.S. Income Taxation And Its Effect On Tax Distribution, Henry Ordower 2015 Northwestern University School of Law

Schedularity In U.S. Income Taxation And Its Effect On Tax Distribution, Henry Ordower

Northwestern University Law Review

No abstract provided.


What A History Of Tax Withholding Tells Us About The Relationship Between Statutes And Constitutional Law, Anuj C. Desai 2015 Northwestern University School of Law

What A History Of Tax Withholding Tells Us About The Relationship Between Statutes And Constitutional Law, Anuj C. Desai

Northwestern University Law Review

No abstract provided.


A Path To "Inure" Peace: Consolidating The Perplexities Of The Private Inurement And Private Benefit Doctrines, Mark C. Westenberger 2015 Washington University School of Law

A Path To "Inure" Peace: Consolidating The Perplexities Of The Private Inurement And Private Benefit Doctrines, Mark C. Westenberger

Washington University Law Review

No abstract provided.


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

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 ...


Tax Debt Help – Settlement & Negotiation, Lissa Coffey 2014 University of South Florida

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 Stanford Law School

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 ...


Reconsidering Corporate Tax Privacy, Joshua D. Blank 2014 NYU School of Law

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 ...


The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson 2014 Five Stone Tax Advisers LLC

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

John Ferguson

No abstract provided.


The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson 2014 Five Stone Tax Advisers LLC

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

John Ferguson

No abstract provided.


Formulary Appointment In The U.S. International Income Tax System: Putting Lipstick On A Pig?, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay 2014 J. Reuben Clark Law School, Brigham Young University

Formulary Appointment In The U.S. International Income Tax System: Putting Lipstick On A Pig?, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay

Michigan Journal of International Law

An affiliated corporate group consists of two or more corporations linked by sufficient stock ownership to cause them to function as an economic unit instead of as independent economic actors. Thus, an affiliated corporate group engaged in international business is often referred to as a multinational enterprise (MNE), a term that we will use throughout this Article. When corporate members of an MNE engage in transactions among themselves, the prices they employ (transfer prices) will significantly affect the amount of overall MNE income that is allocated to each member and, hence, to the tax bases of the various countries in ...


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