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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 SelectedWorks

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 ...


An Analysis Of The Federal Income Tax Issues Associated With The Residential Value Of Solar Tariff, Kayci G. Hines 2014 SelectedWorks

An Analysis Of The Federal Income Tax Issues Associated With The Residential Value Of Solar Tariff, Kayci G. Hines

Kayci G Hines

This paper is a legal analysis of the federal tax implications of cross-implementing the residential business model and the Value-of-Solar-Tariff ("VOST") rate designs with regards to solar technologies/energies. This paper discusses the importance of the resident-utility agreement's structural indicators with regards to federal income taxes.

The order of the paper's analysis proceeds as follows. Part I introduces the solar technologies, residential business model, and value of solar tariff rate design concepts. Part I also lays out a roadmap by which the rest of the paper follows. Part II discusses the traditional rate design, net metering, as well ...


The Intersection Of Tax And Bankruptcy: The Mccoy Rule, John Ferguson 2014 SelectedWorks

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

John Ferguson

No abstract provided.


The Origins Of Affirmative Fiscal Action, Mirit Eyal-Cohen 2014 SelectedWorks

The Origins Of Affirmative Fiscal Action, 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 less efficient or economically inferior survived. Its superior counterpart did not. The article reviews the reasons for this paradox. It shows that the reason is 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.


Multiple Myopias, Multiple Selves, And The Under-Saving Problem, Daniel Shaviro 2014 NELLCO

Multiple Myopias, Multiple Selves, And The Under-Saving Problem, Daniel Shaviro

New York University Law and Economics Working Papers

In both public policy debate and the academic literature, there is widespread, though not universal, agreement that millions of Americans are saving too little for their own retirements. If this is true, we could potentially increase such individuals’ welfare through the adoption of policies that resulted in their saving more. A key dilemma, however, is that, unless one understands why people are under-saving, it is hard to evaluate the likely responses to or merits of a given policy.

Possible explanations for systematic under-saving include at least the following: (1) naïve myopia, (2) sophisticated or self-aware myopia, (3) procrastination, or putting ...


United States National Report On Exchange Of Information, Joshua D. Blank, Ruth Mason 2014 NELLCO

United States National Report On Exchange Of Information, Joshua D. Blank, Ruth Mason

New York University Law and Economics Working Papers

This National Report was prepared for the 2014 Annual Congress of the European Association of Tax Law Professors, which took place in May 2014 at Koç University, Istanbul, Turkey. This National Report discusses administrative and legal mechanisms, especially the Foreign Account Tax Compliance Act (FATCA), that the United States has deployed to obtain offshore tax information. Portions of this National Report were originally published in Joshua D. Blank and Ruth Mason, “Exporting FATCA,” 142 Tax Notes 1245 (2014).


Revenue, U.S. Government, Bert Chapman 2014 Purdue University

Revenue, U.S. Government, Bert Chapman

Libraries Faculty and Staff Scholarship and Research

Provides a historical overview of U.S. Government revenue receipts and spending during the early years of national history. Presents revenue generation statistics, information on revenue sources, and information on domestic and international political and economic factors affecting government revenue receipts.


Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham 2014 Pace University

Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham

Pace Law Review

In order to promote both equality and efficiency, this Comment proposes that individuals should have the opportunity to file jointly for tax and bankruptcy purposes when they have a relationship predicated upon economic interdependence, as opposed to basing the opportunity to file jointly upon marital status. Part I of this Comment will briefly discuss the history of marriage in the United States. In particular, Part I will discuss the role that the government has had in promoting and regulating marriage and how the treatment of married persons operates to the exclusion of the unmarried. Parts II and III of this ...


Heal The Suffering Children: Fifty Years After The Declaration Of War On Poverty, Francine J. Lipman, Dawn Davis 2014 Boston College Law School

Heal The Suffering Children: Fifty Years After The Declaration Of War On Poverty, Francine J. Lipman, Dawn Davis

Boston College Journal of Law & Social Justice

Fifty years ago, President Lyndon B. Johnson declared the War on Poverty. Since then, the federal tax code has been a fundamental tool in providing financial assistance to poor working families. Even today, however, thirty-two million children live in families that cannot support basic living expenses, and sixteen million of those live in extreme poverty. This Article navigates the confusing requirements of an array of child-related tax benefits including the dependency exemption deduction, head of household filing status, the Earned Income Tax Credit, and the Child Tax Credit. Specifically, this Article explores how altering the definition of a qualifying child ...


Legal Mirrors Of Entrepreneurship, Mirit Eyal-Cohen 2014 Boston College Law School

Legal Mirrors Of Entrepreneurship, Mirit Eyal-Cohen

Boston College Law Review

Small businesses are regarded as the engine of the economy. But just what is a “small business”? Depending on where one looks in the law, the definitions vary. Routinely, though, these various classifications fail to assess the policy considerations and legislative intent for granting regulatory preferences to small concerns to begin with. In the last century, the U.S. government has been cultivating one such policy of fiscal and economic growth. Consequently, Congress and private institutions have been acting to incentivize, support, and reward entrepreneurship through the law to stimulate the economy. Nevertheless, rather than targeting entrepreneurial businesses directly, the ...


Tax Vs. Penalty, Round Two: Interpreting The Aca’S Assessable Payment As A Tax For Federal Award Cost Allowances, Riley Lovendale 2014 Boston College Law School

Tax Vs. Penalty, Round Two: Interpreting The Aca’S Assessable Payment As A Tax For Federal Award Cost Allowances, Riley Lovendale

Boston College Law Review

The Patient Protection and Affordable Care Act (ACA)—a significant health care reform enacted in 2010—imposes an “assessable payment” on certain employers that fail to offer affordable health insurance to their employees. Unfortunately, this assessable payment label presents a problem for nonprofits and other nonfederal entities receiving federal awards. Per uniform guidance from the Office of Management and Budget, federal awards may be used to pay taxes, but not fines or penalties. This Note argues that the ACA’s assessable payment should be interpreted as a tax. This conclusion is based on both: (1) the U.S. Supreme Court ...


The Affordable Care Act And Its Impact On The Professional Tax Preparation Market In Kingsport, Tennessee, Robert S. Forney Jr. 2014 East Tennessee State University

The Affordable Care Act And Its Impact On The Professional Tax Preparation Market In Kingsport, Tennessee, Robert S. Forney Jr.

Undergraduate Honors Theses

The objective of this study is to test whether the Affordable Care Act will have an effect on the professional tax preparation industry of Kingsport, Tennessee. To accomplish this objective, the researcher collected surveys concerning taxpayers’ initial reaction to the realization that the law affects their 1040. A two proportion test for equality was performed and failed to reject the idea that the ACA will have an effect on the tax preparation industry of Kingsport. Because this study failed to prove that the change in legislation causes a jump in clientele for the professional tax preparation market, the fight for ...


The Vanishing Of The African-American Family: “Reasonable Efforts” And Its Connection To The Disproportionality Of The Child Welfare System., Stephanie M. Ledesma 2014 SelectedWorks

The Vanishing Of The African-American Family: “Reasonable Efforts” And Its Connection To The Disproportionality Of The Child Welfare System., Stephanie M. Ledesma

Stephanie M Ledesma

ABSTRACT

In the United States, approximately three million cases of child abuse and neglect involving more than six million children are reported annually to child protective service agencies.[1] Our children are in need of protection. But what or who are they in need of protection from? This article suggest until there is a bright line definition for “reasonable efforts” and until there is consistent application of “reasonable efforts”, our children stand desperately in need of protection from the very child protective service agencies that are charged with protecting them.

While there are many articles debating the existence of racial ...


Tax Issues Facing Clients Of Legal Services, T. Keith Fogg 2014 Villanova University School of Law

Tax Issues Facing Clients Of Legal Services, T. Keith Fogg

T. Keith Fogg

This article seeks to highlight tax issues facing clients of legal services. It discusses several specific issues that routinely arise. The article also discusses some of the challenges facing attorneys within legal services that take on a tax clinic and offers some advice on how to address those challenges.


Income Or Liability: How Casinos' Classification Of Outstanding Chips Determine Taxability, John Bulloch 2014 University of Nevada, Las Vegas -- William S. Boyd School of Law

Income Or Liability: How Casinos' Classification Of Outstanding Chips Determine Taxability, John Bulloch

UNLV Gaming Law Journal

No abstract provided.


Does Federal Spending 'Coerce' States? Evidence From State Budgets, Brian D. Galle 2014 Boston College Law School

Does Federal Spending 'Coerce' States? Evidence From State Budgets, Brian D. Galle

Boston College Law School Faculty Papers

According to a recent plurality of the U.S. Supreme Court, the danger that federal taxes will “crowd out” state revenues justifies aggressive judicial limits on the conditions attached to federal spending. Economic theory offers a number of reasons to believe the opposite: federal revenue increases may also float state boats. To test these competing claims, I examine for the first time the relationship between total federal revenues and state revenues. I find that, contra the NFIB plurality, increases in federal revenue -- controlling, of course, for economic performance and other factors -- are associated with a large and statistically significant increase ...


Uncharitable Hospitals: Why The Irs Needs Intermediate Sanctions To Regulate Tax-Exempt Hospitals, Rachel Weisblatt 2014 Boston College Law School

Uncharitable Hospitals: Why The Irs Needs Intermediate Sanctions To Regulate Tax-Exempt Hospitals, Rachel Weisblatt

Boston College Law Review

Tax-exempt hospitals receive millions of dollars worth of tax breaks each year for the purpose of providing care to their communities. Despite these tax breaks, however, there is little evidence to suggest that such breaks significantly benefit the hospitals’ communities. When a hospital no longer meets the federal standard for tax exemption, the Internal Revenue Service currently has two enforcement options: (1) do nothing; or (2) move to revoke the hospital’s tax-exempt status. Revocation, however, is a harsh option that is not appropriate for every circumstance where a hospital fails to meet one or more of the requirements for ...


State “Subsidies” And Unnecessary Public Funding: The Texas Legislature’S Successful Restriction Of Constitutional Rights In Department Of Texas V. Texas Lottery Commission, Tyler A. Dever Ms. 2014 SelectedWorks

State “Subsidies” And Unnecessary Public Funding: The Texas Legislature’S Successful Restriction Of Constitutional Rights In Department Of Texas V. Texas Lottery Commission, Tyler A. Dever Ms.

Tyler A Dever Ms.

This Note argues that the Act’s political advocacy restrictions are unconstitutional as applied to the Plaintiffs in Texas Lottery. This Note discusses government subsidies, occupational licenses, and the doctrine of unconstitutional conditions. It then analyzes the charitable organizations’ First Amendment rights in light of the challenged Act. Although this Note argues against the majority’s upholding of the Act, it will also present flaws in the plaintiffs’ argument for injunction and explain why the court may have ruled in favor of the state.


Less Is More: Applying A Modified Reasonable Compensation Standard To Eliminate The Inconsistencies In The Payroll And Net Investment Income Tax Bases, John S. Treu 2014 SelectedWorks

Less Is More: Applying A Modified Reasonable Compensation Standard To Eliminate The Inconsistencies In The Payroll And Net Investment Income Tax Bases, John S. Treu

John S. Treu

The original policy for the implementation of payroll taxes was to impose a tax on wages as both a funding mechanism for, and a limitation to, qualifying for social security. However, the self-employment tax base developed severe inconsistencies with this original policy and among different tax entities by including certain returns on capital investments in the tax base. At present, different payroll tax obligations arise for similarly situated tax payers based solely on the type of entity the owner elects to be taxed as under the check-the-box regulations. These inconsistencies resulted from misguided efforts by congress and the treasury to ...


Exporting Fatca, Joshua D. Blank, Ruth Mason 2014 NELLCO

Exporting Fatca, Joshua D. Blank, Ruth Mason

New York University Law and Economics Working Papers

The Foreign Account Tax Compliance Act (FATCA) represents a powerful response by the United States to flagrant offshore tax evasion. Although the new reporting regime has been criticized as unilateral and extraterritorial, this short article, prepared for a symposium hosted by Pepperdine Law Review, shows that multilateralism and cooperation so far have been the keys to implementing FATCA. In addition to spurring bilateral Intergovernmental Agreements (IGAs) to implement FATCA, and copycat legislation in other jurisdictions, for many countries, the FATCA reporting requirements represent an aspirational new global standard for automatic exchange of information – one that would supplement, if not replace ...


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