Universitas Indonesia
University of Baltimore School of Law
Universidad de La Salle, Bogotá
Georgetown University Law Center
University of Michigan Law School
San Jose State University
Vanderbilt University Law School
Brief Of The Petitioners-Taxpayers Edward A. And Doris Zelinsky,
2023
Benjamin N. Cardozo School of Law
Brief Of The Petitioners-Taxpayers Edward A. And Doris Zelinsky, Edward A. Zelinsky
Amicus Briefs
As a matter of state law, New York’s own regulations and case law do not permit taxation of Professor Zelinsky’s income earned at home in Connecticut for the COVID-19 period starting on March 15, 2020. Even if New York law permitted the taxation of Professor Zelinsky’s Cardozo salary during this COVID-19 period, as a matter of federal constitutional law, the Due Process and dormant Commerce Clauses do not permit New York’s taxation of this salary earned in Connecticut. In addition, Zelinsky v. Tax Appeals Tribunal, 1 N.Y. 3d 85 (2003), cert. denied, 541 U.S. 1009 (2004), does not apply to …
On The Fence About Immigration And Overpopulation: "Environmentalists" Challenge Dhs Policies On Nepa Basis In Whitewater Draw Natural Resource Conservation District V. Mayorkas,
2023
Villanova University Charles Widger School of Law
On The Fence About Immigration And Overpopulation: "Environmentalists" Challenge Dhs Policies On Nepa Basis In Whitewater Draw Natural Resource Conservation District V. Mayorkas, Maya J. Williams
Villanova Environmental Law Journal
No abstract provided.
Federal Income Taxation,
2023
Mercer University School of Law
Federal Income Taxation, Andrew Todd
Mercer Law Review
In 2022, the United States Court of Appeals for the Eleventh Circuit issued two published opinions involving U.S. federal income tax issues. The first opinion, Sarma v. Commissioner, addressed procedural issues arising under the unified partnership audit procedures that were added to the Internal Revenue Code by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). The second opinion, Kroner v. Commissioner, addressed an issue of first impression in this circuit concerning supervisory review of tax penalties. This Article surveys both of those opinions.
Too Small To Succeed: How Small Nonprofits Are Disadvantaged By The Unrelated Business Income Tax,
2023
Brooklyn Law School
Too Small To Succeed: How Small Nonprofits Are Disadvantaged By The Unrelated Business Income Tax, Rebeka Cohan
Brooklyn Law Review
This note explores the unrelated business income tax (UBIT) and its unfair impact on smaller, less well-funded nonprofits. Although typically exempt from taxation, nonprofits can still be subject to the unrelated business income tax. Nonprofits are subject to UBIT when they have income that (1) qualifies as a trade or business, (2) is regularly carried on, and (3) is not substantially related to its tax-exempt purpose. This note argues that small nonprofits are unfairly disadvantaged by UBIT, because they typically have low budgets and small staffs without legal counsel. Congress should update the Internal Revenue Code (IRC) so organizations that …
Front Matter (Letter From The Editor, Masthead, Etc.),
2023
San Jose State University
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
Mst Program Webinar On November 18, 2022,
2023
San Jose State University
Mst Program Webinar On November 18, 2022, Eric Shao Cpa
The Contemporary Tax Journal
No abstract provided.
The 28th Annual Tax Practitioner/Fall Irs Seminar On October 26, 2022,
2023
San Jose State University
The 28th Annual Tax Practitioner/Fall Irs Seminar On October 26, 2022, Michelle Buchner, Inessa Zlobina
The Contemporary Tax Journal
No abstract provided.
The 38th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov 7 – 8, 2022,
2023
San Jose State University
The 38th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov 7 – 8, 2022, Inessa Zlobina, Enas J. Al-Mais, Aizhan Toibazarova, Tiago Iorio
The Contemporary Tax Journal
No abstract provided.
H.R. 6392 (117th Congress) – No Tax Breaks For Drug Ads Act,
2023
San Jose State University
H.R. 6392 (117th Congress) – No Tax Breaks For Drug Ads Act, Inessa Zlobina, Yan Rapisura
The Contemporary Tax Journal
No abstract provided.
S. 4691 (117th Congress) – Volunteer Driver Tax Parity Act Of 2022,
2023
San Jose State University
S. 4691 (117th Congress) – Volunteer Driver Tax Parity Act Of 2022, Mst Students Bus 223a Spring 2023
The Contemporary Tax Journal
No abstract provided.
H.R. 2863 (117th Congress) – First-Time Homebuyer Act Of 2021,
2023
San Jose State University
H.R. 2863 (117th Congress) – First-Time Homebuyer Act Of 2021, Nina Kramarenko, Gelena Shvetsova
The Contemporary Tax Journal
No abstract provided.
S. 3191 (117th Congress) – Everyday Philanthropist Act,
2023
San Jose State University
S. 3191 (117th Congress) – Everyday Philanthropist Act, Jakub Hench, Tiago Iorio, Ronald Le
The Contemporary Tax Journal
No abstract provided.
Sjsu Mst Information,
2023
San Jose State University
The Case Against The Debt Tax,
2023
Brooklyn Law School
The Case Against The Debt Tax, Vijay Raghavan
Fordham Law Review
Americans are increasingly agitating for debt relief. In the last decade, there have been national campaigns to cancel student debt, credit card debt, and mortgage debt. These national campaigns have paralleled local efforts to cancel taxi medallion debt, carceral debt, and lunch debt. But as the public increasingly pursues broad-scale debt relief outside bankruptcy, they face an important institutional obstacle: canceled debt is generally taxable.
The taxability of canceled debt is often raised by opponents as an objection to broad debt cancellation and potentially discounts the value of any debt relief. The conventional account for why we tax canceled debt …
Fake News And The Tax Law,
2023
University of North Carolina School of Law
Fake News And The Tax Law, Kathleen Delaney Thomas, Erin Scharff
Washington and Lee Law Review
The public misunderstands many aspects of the tax system. For example, people frequently misunderstand how marginal tax rates work, misperceive their own average tax rates, and believe they benefit from tax deductions for which they are ineligible. Such confusion is understandable given the complexity of our tax laws. Unfortunately, research suggests these misconceptions shape voter preferences about tax policy which, in turn, impact the policies themselves.
That people are easily confused by taxes is nothing new. With the rise of social media platforms, however, the speed at which misinformation campaigns can now move to shape public opinion is far faster. …
Stay Schemin’: Tax Court’S Recent Ruling On Credit Card Rewards And The Impact This Ruling Has On Future Rewards Programs,
2023
University of Georgia School of Law
Stay Schemin’: Tax Court’S Recent Ruling On Credit Card Rewards And The Impact This Ruling Has On Future Rewards Programs, Hunter Davis
Georgia Law Review
Beyond the utility of actual “credit,” the most important perk cardholders seek to capitalize on are the rewards that each cardholder’s particular credit card offers. Cardholders look for the most bang for their buck in terms of rewards and points. Ranging from frequent flyer miles to cash back to everything in between, rewards programs have expanded and diversified rapidly over the past several decades, and consumers cannot get enough. So much so that the question of whether, and when, consumer loyalty rewards should be taxable has arisen and persists today. The Internal Revenue Service (IRS) and the Tax Court have …
Standing On The Shoulders Of Llcs: Tax Entity Status And Decentralized Autonomous Organizations,
2023
Loyola University Chicago School of Law
Standing On The Shoulders Of Llcs: Tax Entity Status And Decentralized Autonomous Organizations, Samuel D. Brunson
Georgia Law Review
Since the formation of the first decentralized autonomous organization in 2016, their use has exploded. Thousands of DAOs now try to take advantage of smart contracts to solve a problem that plagues business entities: the gulf between ownership and management. Armed with smart contracts and requiring token-holders to vote on any change in strategy, DAOs dispense with the management layer so necessary in traditional business entities.
DAOs owe their existence to technology. Without blockchain, without cryptocurrency, and without smart contracts, there would be no DAOs. But they owe their explosive to something much more unexpected: Treasury regulations.
In the wake …
Shifting The Scope Towards Students: An Analysis Of Tax Code Treatment Of The Higher Education Loan Interest Deduction,
2023
West Virginia University College of Law
Shifting The Scope Towards Students: An Analysis Of Tax Code Treatment Of The Higher Education Loan Interest Deduction, Brianna C. Frontuto
West Virginia Law Review
In a nation where education is held in the highest regard but given the lowest priority, the United States continues to enlarge a gaping hole in the education system: student loan debt, a crisis sweeping across the nation and affecting nearly every individual in the United States. Higher education costs have sky-rocketed, and the expanding administrations and complex projects do not provide assurance that this will change any time soon.
Congress has placed tax incentives in the Internal Revenue Code (“the Code”) to encourage the pursuit of higher education while providing a benefit for doing so. Specifically, § 221 of …
Force Majeure & Covid-19: A Clause Changed?,
2023
DePaul University College of Law
Force Majeure & Covid-19: A Clause Changed?, Claudia Petcu
DePaul Business & Commercial Law Journal
No abstract provided.
The Kinder, Gentler Irs? Where?,
2023
University of Hartford
The Kinder, Gentler Irs? Where?, Harvey Gilmore
DePaul Business & Commercial Law Journal
No abstract provided.
