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Federal Income Taxation, Nikolai Karetnyi, Ruoxi Zhang 2020 Mercer University School of Law

Federal Income Taxation, Nikolai Karetnyi, Ruoxi Zhang

Mercer Law Review

In the year 2019, the federal courts within the Eleventh Circuit handed down several notable opinions on federal tax issues. This Article surveys two of those opinions involving the taxation of shareholder loans to S corporations and the application of gross valuation-misstatement penalty to partnerships.


“Do No Harm Or Injustice To Them”: Indicting And Convicting Physicians For Controlled Substance Distribution In The Age Of The Opioid Crisis, Julia B. MacDonald 2020 University of Maine School of Law

“Do No Harm Or Injustice To Them”: Indicting And Convicting Physicians For Controlled Substance Distribution In The Age Of The Opioid Crisis, Julia B. Macdonald

Maine Law Review

In response to the devastating impact of the opioid crisis, the Department of Justice has in recent years launched an aggressive crackdown on what it characterizes as “fraudulent prescribers” of controlled substances. Against this backdrop, physicians, prosecutors, and defense attorneys face a number of issues. First, there is a lingering circuit court split on the issue of whether indictments against physicians and other medical professionals for illegal controlled substance distribution must allege that the physician acted “outside the usual course of professional practice and without a legitimate medical purpose.” I argue that acting without a legitimate medical purpose is an ...


Blockchain Technology And The Irs: How The Use Of Blockchain Technology Could Interfere With A Taxpayer’S Privacy Rights, Michelle Yang 2020 Golden Gate University School of Law

Blockchain Technology And The Irs: How The Use Of Blockchain Technology Could Interfere With A Taxpayer’S Privacy Rights, Michelle Yang

Blockchain Law

We will examine the benefits and dangers of implementing blockchain technology within the IRS framework. In the context of filing and reviewing tax returns, implementing blockchain technology within the tax industry could soften the relationship between the government, particularly with the IRS, and the taxpayer with speedier refunds, more efficient communications, and a uniform effort to deal with controversy more effectively. Part II will provide a brief background on the pros and cons of using blockchain technology to file tax returns. Parts III and IV will focus on two of the current laws governing cyberspace technology and how each law ...


Racialized Tax Inequity: Wealth, Racism, And The U.S. System Of Taxation, Palma Joy Strand, Nicholas A. Mirkay 2020 Creighton University

Racialized Tax Inequity: Wealth, Racism, And The U.S. System Of Taxation, Palma Joy Strand, Nicholas A. Mirkay

Northwestern Journal of Law & Social Policy

This Article describes the connection between wealth inequality and the increasing structural racism in the U.S. tax system since the 1980s. A long-term sociological view (the why) reveals the historical racialization of wealth and a shift in the tax system overall beginning around 1980 to protect and exacerbate wealth inequality, which has been fueled by racial animus and anxiety. A critical tax view (the how) highlights a shift over the same time period at both federal and state levels from taxes on wealth, to taxes on income, and then to taxes on consumption—from greater to less progressivity. Both ...


A Constitutional Wealth Tax, Ari Glogower 2020 Ohio State University Moritz College of Law

A Constitutional Wealth Tax, Ari Glogower

Michigan Law Review

Policymakers and scholars are giving serious consideration to a federal wealth tax. Wealth taxation could address the harms from rising economic inequality, promote equality of social and economic opportunity, and raise the revenue needed to fund critical government programs. These reasons for taxing wealth may not matter, however, if a federal wealth tax is unconstitutional.

Scholars debate whether a tax on a wealth base (a “traditional wealth tax”) would be a “direct tax” subject to apportionment among the states by population. This Article argues, in contrast, that this possible constitutional restriction on a traditional wealth tax may not matter. If ...


Treatment Of Medicaid Waiver Payments For Purpose Of Eitc And Actc, Xiaoyue (Tina) Tan 2020 San Jose State University

Treatment Of Medicaid Waiver Payments For Purpose Of Eitc And Actc, Xiaoyue (Tina) Tan

The Contemporary Tax Journal

No abstract provided.


Complete America's Great Trails Act S.809 (116th Congress), MST Students BUS 223A Fall 2019 2020 San Jose State University

Complete America's Great Trails Act S.809 (116th Congress), Mst Students Bus 223a Fall 2019

The Contemporary Tax Journal

No abstract provided.


Fun Tax Facts, Rachana Khandelwal 2020 San Jose State University

Fun Tax Facts, Rachana Khandelwal

The Contemporary Tax Journal

No abstract provided.


Taxation Of Early Distributions From A 401(K) Retirement Plan, Liubov (Luba) Shilkova 2020 San Jose State University

Taxation Of Early Distributions From A 401(K) Retirement Plan, Liubov (Luba) Shilkova

The Contemporary Tax Journal

No abstract provided.


Tax Law's Workplace Shift, Shu-Yi Oei, Diane M. Ring 2020 Boston College Law School

Tax Law's Workplace Shift, Shu-Yi Oei, Diane M. Ring

Boston College Law School Faculty Papers

In December 2017, Congress passed major tax reform. The reform included an important new provision that granted independent contractors and other pass-through taxpayers—but not employees or corporations—a potential tax deduction equal to 20% of their qualified business income. Critics have argued that this new deduction (codified at 26 U.S.C. § 199A) could lead to a widespread shift toward independent contractor jobs as workers seek to reduce taxes paid. This shift could cause workers to lose important employee protections and leave them more economically vulnerable.

This Article examines whether this new tax provision will create a large-scale workplace ...


More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis 2020 Mercer University School of Law

More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis

Mercer Law Review

In December of 2017, the United States (U.S.) enacted tax reform commonly known as the “Tax Cuts and Jobs Act” (TCJA), which was initially thought to “establish[] a territorial tax system for multinational companies.” Over time, however, tax professionals began to understand that the TCJA layered a territorial tax system that exempted foreign earnings from the U.S. income tax (exemption tax system) on top of a residence-based worldwide tax system that used a foreign tax credit (FTC) to protect against juridical double taxation (worldwide tax system). Furthermore, the U.S. exemption tax system is severely limited by the ...


Relief For Preachers: The History Of Parsonages And Taxation, Theodore F. DiSalvo 2020 University of St. Thomas, Minnesota

Relief For Preachers: The History Of Parsonages And Taxation, Theodore F. Disalvo

University of St. Thomas Law Journal

No abstract provided.


Taxing Bitcoin And Blockchains—What The Irs Told Us (And What It Didn’T), David J. Shakow 2020 University of Pennsylvania Carey Law School

Taxing Bitcoin And Blockchains—What The Irs Told Us (And What It Didn’T), David J. Shakow

Faculty Scholarship at Penn Law

The IRS recently issued its second description of how it will treat Bitcoin and other blockchain assets. Some of its analysis leaves open questions that invite further consideration, and important issues remain unresolved. Moreover, because the popular Bitcoin blockchain uses a "proof of work" consensus procedure, issues relating to the alternative "proof of stake" procedure have been neglected.


Reversing The Fortunes Of Active Funds, Adi Libson, Gideon Parchomovsky 2020 Bar-Ilan University - Faculty of Law

Reversing The Fortunes Of Active Funds, Adi Libson, Gideon Parchomovsky

Faculty Scholarship at Penn Law

Recent years have witnessed a considerable growth of passive fund at the expense of active funds. This trend picked in 2019, a year that saw passive funds surpass active funds in terms of assets under management. The continuous decline of active funds is a cause for concern. Active funds engage in monitoring of firms and partake of decision-making in companies in their portfolio. The cost of these activities are born exclusively by active funds; the benefits, by contrast, are spread over all shareholders, including passive funds that freeride on the efforts of active funds. The contraction of active funds threatens ...


Something For Nothing: Universal Basic Income And The Value Of Work Beyond Incentives, Jonathan D. Grossberg 2020 Robert Morris University

Something For Nothing: Universal Basic Income And The Value Of Work Beyond Incentives, Jonathan D. Grossberg

Washington and Lee Journal of Civil Rights and Social Justice

Proponents and opponents of a universal basic income all acknowledge that the most significant political challenge to its adoption in the United States is that a universal basic income would not have a work requirement attached. Often, this is characterized as a problem involving incentives—the availability of a universal basic income would cause many people to stop working (or significantly curtail the number of hours that they work) and simply live off the universal basic income. This Article makes three contributions to the literature related to a universal basic income: First, it provides a typology for understanding the many ...


Letter From Jeffery M. Kadet And David L. Koontz To Internal Revenue Service (Jan. 16, 2020) On Proposed Regulations Reg-100956-19, Jeffery M. Kadet, David L. Koontz 2020 University of Washington School of Law

Letter From Jeffery M. Kadet And David L. Koontz To Internal Revenue Service (Jan. 16, 2020) On Proposed Regulations Reg-100956-19, Jeffery M. Kadet, David L. Koontz

Articles

No abstract provided.


Book Review, Roberto Rosas 2020 St. Mary's University School of Law

Book Review, Roberto Rosas

St. Mary's Law Journal

Abstract forthcoming.


Back To The Future: Marriage And Divorce Under The 2017 Tax Act, Mark Cochran 2020 St. Mary's University School of Law

Back To The Future: Marriage And Divorce Under The 2017 Tax Act, Mark Cochran

St. Mary's Law Journal

Abstract forthcoming


Tax In The 2020 Presidential Election, Ryan G. Quinn 2020 University of New Hampshire, Durham

Tax In The 2020 Presidential Election, Ryan G. Quinn

Honors Theses and Capstones

No abstract provided.


The Dormant Foreign Commerce Clause After Wynne, Michael S. Knoll, Ruth Mason 2020 University of Pennsylvania Carey Law School

The Dormant Foreign Commerce Clause After Wynne, Michael S. Knoll, Ruth Mason

Faculty Scholarship at Penn Law

This Essay surveys dormant foreign Commerce Clause doctrine to determine what limits it places on state taxation of international income, including both income earned by foreigners in a U.S. state and income earned by U.S. residents abroad. The dormant Commerce Clause similarly limits states’ powers to tax interstate and foreign commerce; in particular, it forbids states from discriminating against interstate or international commerce. But there are differences between the interstate and foreign commerce contexts, including differences in the nationality of affected taxpayers and differences in the impact of state taxes on federal tax and foreign-relations goals. Given current ...


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