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1934 full-text articles. Page 1 of 43.

The Negative Capital Account Maze, Walter D. Schwidetzky 2017 University of Baltimore School of Law

The Negative Capital Account Maze, Walter D. Schwidetzky

All Faculty Scholarship

Outside Hubert I and Hubert II, there has been little discussion of negative capital accounts in the tax context and almost no discussion in the nontax context. Nontax law, however, is critically important. This report provides an integrated discussion of the application of tax and nontax law to negative capital accounts.

One of the challenges in writing this report is that it requires a discussion of both the at-risk rules of section 465 and the debt allocation rules of section 752. Complex issues involving sections 465 and 752 and their interaction are worthy of their own articles. Indeed, others have ...


Business Taxes Reinvented: The Dual Business Enterprise Income Tax, Edward D. Kleinbard 2017 University of Southern California

Business Taxes Reinvented: The Dual Business Enterprise Income Tax, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

This short overview and accompanying term sheet summarize the key features of a proposed comprehensive business tax environment termed the Dual Business Enterprise Income Tax (the Dual BEIT). The term sheet format is a useful mode of presentation for capturing in one accessible document the major policy recommendations of the Dual BEIT (or any other comprehensive tax reform proposal).

This paper makes the case that the Dual BEIT satisfies the objectives of policymakers from both parties for comprehensive business tax reform that can serve as the platform for economic growth while collecting appropriate levels of tax revenue. The arguments are ...


The Tax Lives Of Uber Drivers: Evidence From Online Forums, Diane M. Ring, Shu-Yi Oei 2017 Boston College Law School

The Tax Lives Of Uber Drivers: Evidence From Online Forums, Diane M. Ring, Shu-Yi Oei

Shu-Yi Oei

In this Article, we investigate the tax issues and challenges facing Uber and Lyft drivers by studying their online interactions in three internet discussion forums: Reddit.com, Uberpeople.net, and Intuit TurboTax AnswerXchange. Using descriptive statistics and content analysis, we examine (1) the substantive tax concerns facing forum participants, (2) how taxes affect their driving and profitability decisions, and (3) the degree of user sophistication, accuracy of legal advising, and other cultural features of the forums.

We find that while forum participants displayed generally accurate understandings of tax filing and income inclusion obligations, their approaches to expenses and deductions were ...


A Practical Solution To The Marriage Penalty, Margaret Ryznar 2017 Pepperdine University

A Practical Solution To The Marriage Penalty, Margaret Ryznar

Pepperdine Law Review

In the federal income tax code, there is a marriage penalty resulting from tax brackets that do not double upon marriage. This marriage penalty persists despite universal condemnation of it, penalizing a significant portion of married women who work and many same-sex couples. This Article proposes a novel way to deal with this marriage penalty by creating a filing status for dual income couples that earn an amount within a particular percentage of each other. This filing status would be the same as the current married filing status, except it would double the rates of single filers by accommodating two ...


Cpa Exam Review, 2017 San Jose State University

Cpa Exam Review

The Contemporary Tax Journal

No abstract provided.


Front Matter (Letter From The Editor, Masthead, Etc.), 2017 San Jose State University

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


Country By Country Reporting Under Beps, Fenny Lei 2017 San Jose State University

Country By Country Reporting Under Beps, Fenny Lei

The Contemporary Tax Journal

No abstract provided.


U.S. Tax Forms For American Expatriates, Saqib Amin CPA 2017 San Jose State University

U.S. Tax Forms For American Expatriates, Saqib Amin Cpa

The Contemporary Tax Journal

No abstract provided.


Bringing The U.S. Tax Court Exam Out Of Obscurity, Lucia Nasuti Smeal J.D., Tad D. Ransopher J.D. 2017 Georgia State University

Bringing The U.S. Tax Court Exam Out Of Obscurity, Lucia Nasuti Smeal J.D., Tad D. Ransopher J.D.

The Contemporary Tax Journal

No abstract provided.


Summaries For The 32nd Annual Tei-Sjsu High Tech Tax Institute, Saqib Amin, Silin Chen, Ophelia Ding, Veena Hemachandran, Elle San Pedro de Kornsand, Padmini Yalamarthi, Yu Zheng 2017 San Jose State University

Summaries For The 32nd Annual Tei-Sjsu High Tech Tax Institute, Saqib Amin, Silin Chen, Ophelia Ding, Veena Hemachandran, Elle San Pedro De Kornsand, Padmini Yalamarthi, Yu Zheng

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal Volume 6, No. 2 – Spring 2017, 2017 San Jose State University

The Contemporary Tax Journal Volume 6, No. 2 – Spring 2017

The Contemporary Tax Journal

No abstract provided.


Taxing Marijuana: Earmarking Tax Revenue From Legalized Marijuana, Armikka R. Bryant 2017 Washington State Office of the Attorney General

Taxing Marijuana: Earmarking Tax Revenue From Legalized Marijuana, Armikka R. Bryant

Georgia State University Law Review

This Article provides an overview of the legal, political, and societal landscapes in states that have legalized marijuana and imposed taxes on its sale. The article begins by summarizing the War on Drugs’ origins, its fiscal expenditures, and the social policies that ultimately led to its failure.

Part I briefly details the history of marijuana regulation starting from the early twentieth century up to the Obama administration’s decision to permit recreational marijuana laws to stand in Washington state and Colorado. Part II dives deeper into the social costs of the War on Drugs and outlines the hardships faced by ...


Capital Taxation In An Age Of Inequality, Edward D. Kleinbard 2017 University of Southern California

Capital Taxation In An Age Of Inequality, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

The standard view in the U.S. tax law academy remains that capital income taxation is both a poor idea in theory and completely infeasible in practice. But this ignores the first-order importance of political economy issues in the design of tax instruments. The pervasive presence of gifts and bequests renders moot the claim that the results obtained by Atkinson and Stiglitz (1976) counsel against taxing capital income in practice.

Taxing capital income is responsive to important political economy exigencies confronting the United States, including substantial tax revenue shortfalls relative to realistic government spending targets, increasing income and wealth inequality ...


Newsroom: Donald Trump Vs. Roger Williams 05-09-2017, David Logan 2017 Roger Williams University School of Law

Newsroom: Donald Trump Vs. Roger Williams 05-09-2017, David Logan

Life of the Law School (1993- )

No abstract provided.


Rwu First Amendment Blog: David A. Logan's Blog: Donald Trump Vs. Roger Williams 05-08-2017, David A. Logan 2017 Roger Williams University School of Law

Rwu First Amendment Blog: David A. Logan's Blog: Donald Trump Vs. Roger Williams 05-08-2017, David A. Logan

Law School Blogs

No abstract provided.


Statutory Interpretation Lessons Courtesy Of Pilgrim’S Pride, Philip G. Cohen 2017 University of Miami Law School

Statutory Interpretation Lessons Courtesy Of Pilgrim’S Pride, Philip G. Cohen

University of Miami Business Law Review

In Pilgrim’s Pride Corp. v. Commissioner, the Fifth Circuit reversed the Tax Court and held that the taxpayer was entitled to an ordinary loss deduction from its abandonment of securities. While the conclusion reached by the Fifth Circuit has been overshadowed by the promulgation of Treasury Regulation section 1.165-5(i) that effectively treats an abandoned security as worthless and thus characterizes the loss as capital, the case remains noteworthy because it provides an opportunity to examine the statutory interpretation of two distinct Internal Revenue Code sections, section 165(g)(1) and section 1234A. The article focuses on what ...


Taxation, Competitiveness, And Inversions: A Response To Kleinbard, Michael S. Knoll 2017 University of Pennsylvania Law School

Taxation, Competitiveness, And Inversions: A Response To Kleinbard, Michael S. Knoll

Faculty Scholarship

In this report, I argue that the inversion situation is more nuanced, complex, and ambiguous than Edward D. Kleinbard acknowledges, and I challenge Kleinbard’s claim that U.S. multinationals are on a tax par with their foreign competitors.


Partnership Tax Allocations: The Basics, Walter D. Schwidetzky 2017 University of Baltimore School of Law

Partnership Tax Allocations: The Basics, Walter D. Schwidetzky

All Faculty Scholarship

This article endeavors to help practitioners who are not partnership tax allocation experts identify when they should consult with those with that expertise. The partnership-allocation Treasury Regulations have been called "a creation of prodigious complexity ... essentially impenetrable to all but those with the time, talent, and determination to become thoroughly prepared experts on the subject." This article is written for those, to date at least, without that time and determination. At the same time, the article provides an introduction to the partnership tax allocation rules for those contemplating making the requisite investment of time and determination.

The term "partnership," for ...


What Might Tax Reform Look Like?, Donald Roth 2017 Dordt College

What Might Tax Reform Look Like?, Donald Roth

Faculty Work: Comprehensive List

"When it comes to tax reform, it has been most consistently successful when lower rates are coupled with reduced complexity and closed loopholes."

Posting about changing American tax plans from In All Things - an online journal for critical reflection on faith, culture, art, and every ordinary-yet-graced square inch of God’s creation.

http://inallthings.org/what-might-tax-reform-look-like/


5 Things You May Not Know About Our Tax System, Donald Roth 2017 Dordt College

5 Things You May Not Know About Our Tax System, Donald Roth

Faculty Work: Comprehensive List

"Let’s take a look at some important features of our tax system of which you might not be aware."

Posting about current American tax practices from In All Things - an online journal for critical reflection on faith, culture, art, and every ordinary-yet-graced square inch of God’s creation.

http://inallthings.org/5-things-you-may-not-know-about-our-tax-system/


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