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Partnership Tax Provisions Of The Tcja As Illustrations Of Planning Simplification Versus Compliance Simplification Trade-Offs, Emily Cauble 2021 Pepperdine University

Partnership Tax Provisions Of The Tcja As Illustrations Of Planning Simplification Versus Compliance Simplification Trade-Offs, Emily Cauble

Pepperdine Law Review

Oftentimes, efforts to simplify the process of reporting the tax consequences of events that have already occurred exacerbate complexity faced by taxpayers at the stage in time when they are deciding how to act. Efforts to simplify reporting include, for instance, provisions that obviate the need to value assets prior to their sale or methods for determining tax consequences that reduce the number of computational steps used when determining tax liability. While such efforts may, to a degree, simplify tax compliance, they can also set traps for unwary taxpayers at the planning stage. Avoiding asset valuation or taking short-cuts when ...


Taxing The Ivory Tower: Evaluating The Excise Tax On University Endowments, Jennifer Bird-Pollan 2021 Pepperdine University

Taxing The Ivory Tower: Evaluating The Excise Tax On University Endowments, Jennifer Bird-Pollan

Pepperdine Law Review

The Tax Cuts and Jobs Act of 2017 introduced the first-ever excise tax imposed on the investment income of university endowments. While it is a relatively small tax, this new law is a first step towards the exploration of taxing non-profit entities on the vast sums of wealth they hold in their endowments. In this essay I take the new tax as a starting place for investigating the justification for tax exemption for universities and thinking through the consequences of changing our approach, both in the form of the new excise tax and possible alternatives. There remain reasons to be ...


May The Odds Be Ever In Your Favor: How The Tax Cuts And Jobs Act Fortified The Great Wealth Divide, Phyllis Taite 2021 Pepperdine University

May The Odds Be Ever In Your Favor: How The Tax Cuts And Jobs Act Fortified The Great Wealth Divide, Phyllis Taite

Pepperdine Law Review

Have Americans become so desensitized to inequality that we have morphed into a state of dystopia, and vast inequalities have become normalized? Discussions of dystopia typically describe acts of oppression, tyranny, inequality, and an overall undesirable societal state. Dystopia analysis also requires a hard look at societal values to determine ways to avoid adverse outcomes that vast inequalities may produce. By identifying the undesirable outcome, there is an opportunity to avoid or reverse it by enacting laws to combat inequalities. The Hunger Games is a fictional tale of wealthy society members enjoying the rewards of high society while using the ...


A Gilti Fix For An Employment Tax Glitch, Richard Winchester 2021 Pepperdine University

A Gilti Fix For An Employment Tax Glitch, Richard Winchester

Pepperdine Law Review

This Article will describe in greater detail the basic contours of such a reform. Before doing so, Part II describes the existing employment tax rules, focusing on the various ways they apply to a self-employed individual. Part III explains how certain self-employed individuals can use the rules to limit their employment tax base and the tax they owe. Part IV describes the distortions and inequities that are produced under the current employment tax rules. Part V recounts legislative efforts to isolate labor income and shows how those efforts came to bear fruit in the GILTI rules and elsewhere in the ...


Intent, Inequality, And The Berlin Walls Of The Mind, Bobby L. Dexter 2021 Pepperdine University

Intent, Inequality, And The Berlin Walls Of The Mind, Bobby L. Dexter

Pepperdine Law Review

Although acknowledging that various provisions in the Tax Cuts and Jobs Act of 2017 appear responsive to normative arguments presented in tax literature, this article posits that, true to its core intent, the law aggressively advanced the persistent effort to shift the tax burden away from the nation’s wealthiest citizens to the great bulk of taxpayers of more modest financial means. Thus, those with political power successfully employed the tax law to protect, preserve, and enhance prevailing wealth and income inequality. With the election of President Joe Biden and the assumption of Democratic control in both chambers of Congress ...


Comparing Capital Income And Wealth Taxes, Ari Glogower 2021 Pepperdine University

Comparing Capital Income And Wealth Taxes, Ari Glogower

Pepperdine Law Review

As part of the Pepperdine Law Review Symposium The Impact of the 2017 Tax Act on Income and Wealth Inequality: Lessons for 2020 and Beyond, this Essay compares two reform directions to rebuild the progressive tax system: an improved capital income tax—which would eliminate the benefit from deferring gains until a sale—or a wealth tax. The Essay first introduces the concept of a “rate-equivalent” wealth or capital income tax as a way to assess reform alternatives consistently and to identify the assumptions as to how the reforms would be structured. For any chosen capital income tax (or wealth ...


Workplace Transformation And Its Tax Compliance Implications, Jay A. Soled 2021 Villanova University Charles Widger School of Law

Workplace Transformation And Its Tax Compliance Implications, Jay A. Soled

Villanova Law Review

No abstract provided.


Charitable Donation Of Deconstructed House Denied, Dimple Mukhi 2021 San Jose State University

Charitable Donation Of Deconstructed House Denied, Dimple Mukhi

The Contemporary Tax Journal

No abstract provided.


Front Matter (Letter From The Editor, Masthead, Etc.), 2021 San Jose State University

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

The Contemporary Tax Journal

No abstract provided.


S. 844 (117th Congress) - Personal Health Investment Today (Phit) Act Of 2021, Neha Nanda, Karla Rees 2021 San Jose State University

S. 844 (117th Congress) - Personal Health Investment Today (Phit) Act Of 2021, Neha Nanda, Karla Rees

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal Volume 10, No. 2 – Summer 2021, 2021 San Jose State University

The Contemporary Tax Journal Volume 10, No. 2 – Summer 2021

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal's Interview With Mr. Andy Mattson, Hana Kwong 2021 San Jose State University

The Contemporary Tax Journal's Interview With Mr. Andy Mattson, Hana Kwong

The Contemporary Tax Journal

No abstract provided.


Roger Cpa Review Questions, Roger Philipp 2021 San Jose State University

Roger Cpa Review Questions, Roger Philipp

The Contemporary Tax Journal

No abstract provided.


Some Credit Card Points Are Taxable, Tam Nguyen 2021 San Jose State University

Some Credit Card Points Are Taxable, Tam Nguyen

The Contemporary Tax Journal

No abstract provided.


The Irs’S Voluntary Disclosure Program: Need For Codification, Jay A. Soled 2021 Rutgers University

The Irs’S Voluntary Disclosure Program: Need For Codification, Jay A. Soled

Georgia State University Law Review

For more than a century, the Internal Revenue Service (IRS) has had a voluntary disclosure program in place. Its purpose is to coax into tax compliance those wayward taxpayers who have committed criminal acts or have been remiss in fulfilling their civic tax-filing obligations. Historically, the voluntary disclosure program has had to strike a difficult balance between being attractive enough to entice tax scofflaws to participate and not being too attractive lest ordinary taxpayers feel that their compliance efforts were for naught.

A unique feature of the voluntary disclosure program is that it is entirely administrative in origin. The commissioner ...


The Tax Implications Of The American Families Plan On Iowa Farmland Owners, Kristine Tidgren, Wendong Zhang 2021 Iowa State University

The Tax Implications Of The American Families Plan On Iowa Farmland Owners, Kristine Tidgren, Wendong Zhang

CARD Policy Briefs

President Biden proposed the American Families Plan (AFP) on April 28, 2021, to provide new social programs to millions of Americans. To pay for this $1.8 trillion benefits package, the AFP proposes significantly changing the way capital gain is taxed. The Administration has explained that “reforms to the taxation of capital gains and qualified dividends will reduce economic disparities among Americans and raise needed revenue.” Specifically, the AFP proposes increasing the top marginal tax rate, taxing some capital gain at ordinary income tax rates, and subjecting more gain to the 3.8% Medicare tax. The AFP would thus boost ...


Puff, Puff, Tax: Internal Revenue Code Section 280e Penalizes State-Sanctioned Marijuana Companies And Undermines The Ability-To-Pay Principle, Joseph E. Thomas 2021 Villanova University Charles Widger School of Law

Puff, Puff, Tax: Internal Revenue Code Section 280e Penalizes State-Sanctioned Marijuana Companies And Undermines The Ability-To-Pay Principle, Joseph E. Thomas

Villanova Law Review

No abstract provided.


A State-Level Response To Ineffective Federal Place-Based Investment Tax Incentives, Michelle Chaing Perry 2021 Boston College Law School

A State-Level Response To Ineffective Federal Place-Based Investment Tax Incentives, Michelle Chaing Perry

Boston College Law Review

Using tax expenditures, the federal government can deploy economic incentives to alter our choices in the service of public policy goals. Doing so reduces not only federal but also state tax revenue because state tax law often conforms to definitions of income contained in the Internal Revenue Code. State governments, however, may not have the same goals as Congress, so tax incentives implemented nationally may not always be a good fit for states. This Note focuses on tax expenditures directing private investments into low-income neighborhoods, known as federal place-based investment tax incentives. It argues that because their impact is ambiguous ...


The Unfair Treatment Of Cryptocurrencies By The U.S. Internal Revenue Service, Antonio Alverez Lorenzo 2021 Golden Gate University School of Law

The Unfair Treatment Of Cryptocurrencies By The U.S. Internal Revenue Service, Antonio Alverez Lorenzo

Blockchain Law

This paper explores the challenges the cryptocurrency industry has been confronting in the United States due to the unfairness of the tax policies issued by the United States Internal Revenue Service. Cryptocurrency service providers, miners, investors and general consumers are being prevented from taking advantages of special tax treatments as compared to other similar properties, commodities and securities. Tax legislation has not kept pace with the development of emerging cryptocurrency technologies that enable otherwise traditional types of revenue to be generated.


The Challenges Of Nonprofit Governance, Peter Molk, D. Daniel Sokol 2021 University of Florida Levin College of Law

The Challenges Of Nonprofit Governance, Peter Molk, D. Daniel Sokol

Boston College Law Review

The stakes for proper nonprofit governance are extremely high. Over 1.5 million nonprofits are registered with the Internal Revenue Service (IRS), collectively employing twelve million people and accounting for 5.6% of U.S. gross domestic profit. Yet whereas for-profit companies have significant checks on the behavior of boards and management, nonprofit firms lack many of the same types of internal and external governance control mechanisms. COVID-19 is just the latest shock to expose the lack of preparedness and capability of many nonprofit boards in fulfilling their essential governance functions. This Article contributes to the corporate governance literature by ...


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