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Taxation-Federal Income Commons

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Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr. 2015 Notre Dame Law School

Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.

Georgia Journal of International & Comparative Law

No abstract provided.


Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne 2015 University of Georgia School of Law

Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne

Georgia Journal of International & Comparative Law

No abstract provided.


Income Tax Accounting Consistency: Eliminate Accrual And Depreciation, And Revamp The Tax Treatment Of Borrowing, Joseph M. Dodge 2015 Florida State University

Income Tax Accounting Consistency: Eliminate Accrual And Depreciation, And Revamp The Tax Treatment Of Borrowing, Joseph M. Dodge

Joseph M Dodge

Abstract for

INCOME TAX ACCOUNTING CONSISTENCY: ELIMINATE ACCRUAL AND DEPRECIATION, AND REVAMP THE TAX TREATMENT OF BORROWING

Joseph M. Dodge

Professor Emeritus, Florida State University College of Law

The thesis is that inconsistent tax accounting rules undermine the individual income tax, and the best available move for improving it – given the unassailability of the realization principle - is to eliminate its accrual (and quasi-accrual) features. Specifically, the agenda is to eliminate tax accrual accounting in the conventional sense, revamp the tax treatment of borrowing to (inter alia) abolish the Crane doctrine, and eliminate depreciation deductions for indivisible productive assets. The end ...


Lessons In Fiscal Activism, Mirit Eyal-Cohen 2015 University of Alabama School of Law

Lessons In Fiscal Activism, Mirit Eyal-Cohen

Mirit Eyal-Cohen

This article highlights an anomaly. It shows that two tax rules aimed to achieve a similar goal were introduced at the same time. Both meant to be temporary and bring economic stimuli but received a dramatically different treatment. The economically inferior rule survived while its superior counterpart did not. The article reviews the reasons for this paradox. It shows that the causes are both political and an agency problem. The article not only enriches an important and ongoing debate that has received much attention in recent years, but also provides important lessons to policymakers.


Allocative Fairness And The Income Tax, Joseph M. Dodge 2015 Florida State University

Allocative Fairness And The Income Tax, Joseph M. Dodge

Joseph M Dodge

Abstract for: Allocative Fairness and the Income Tax

This article seeks to provide a normative justification for the “allocative tax fairness” principle of “objective ability to pay.” First off is a brief overview of norm categories as they relate to taxation. Here, the category of internal-to-tax fairness (“allocative fairness”), referring to how the tax burden should be apportioned among the population, is identified as being distinct from a conception of a good or just society (social equity). Allocative tax fairness is often referred to as “horizontal equity.” Unfortunately, that notion is purely formal, and the remainder of the article develops ...


The Family Llc: A New Approach To Insuring Dynastic Wealth, Evan M. Purcell 2015 George Mason University

The Family Llc: A New Approach To Insuring Dynastic Wealth, Evan M. Purcell

Evan M Purcell

No abstract provided.


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.


Unveiling The Section 4975(E)(2)(G) Fiduciary Management And Investment Risk Diversification Standards, David Randall Jenkins 2015 Unaffiliated

Unveiling The Section 4975(E)(2)(G) Fiduciary Management And Investment Risk Diversification Standards, David Randall Jenkins

David Randall Jenkins

While the Tax Court’s 2004 Rollins decision recounts §4941(d) private foundation and §4975(c) retirement plan self-dealing activity commonalities, its palpable failure to reconcile important public policy §4946(a)(1)(C) and §4975(e)(2)(G) disqualified person criteria differences implicates an important teaching. This paper deciphers the Tax Court’s Rollins teaching by demonstrating the §4946(a)(1)(C) >20% and §4975(e)(2)(G) ≥50% disqualified person criteria manifest management and investment risk diversification symmetric matrices. The matrices enable important public policy private foundation and retirement plan fiduciary management and investment risk diversification standard general rules ...


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

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.


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