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The Fallacious Objections To The Tax Treatment Of Carried Interest, Douglas A. Kahn, Jeffrey H. Kahn 2017 University of Michigan Law School

The Fallacious Objections To The Tax Treatment Of Carried Interest, Douglas A. Kahn, Jeffrey H. Kahn

Articles

“The tax treatment of carried interest has become a notorious bete noire for many politicians and some academicians and practitioners. Both 2016 presidential candidates denounced the current tax treatment and vowed to change it. President Obama described the current treatment as a "tax loophole" which should be closed. Others have also characterized the current tax treatment as an abusive loophole.' It is the thesis of this article that those criticisms are unfounded. To the contrary, the current tax treatment accords with sound tax policy and is proper and appropriate. Given the broad approval that attended the attacks on carried interest ...


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.


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.


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.


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.


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.


Cpa Exam Review, 2017 San Jose State University

Cpa Exam Review

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.


Comments On Proposed Regulations Concerning Definition Of Dependent, Robert D. Probasco 2017 Texas A&M University School of Law

Comments On Proposed Regulations Concerning Definition Of Dependent, Robert D. Probasco

Robert Probasco

The Working Families Tax Relief Act of 2004 (the “2004 Act”) replaced multiple definitions of “child” utilized for child-related tax benefits within the Code with a uniform definition of “qualifying child” (“UDOC”). Additional changes to the UDOC have been made since 2004, as part of the Gulf Opportunity Zone Act of 2005, and through the Fostering Connections to Success and Increasing Adoptions Act of 2008.

The Section of Taxation previously provided extensive comments on the UDOC, expressing concerns with the UDOC and proposing both legislative and regulatory changes (“UDOC Report”). Some of these concerns were addressed by the Internal Revenue ...


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 ...


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 at Penn Law

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.


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/


How Did We Get Our Tax System? (And What Can That Teach Us About Reforming It?), Donald Roth 2017 Dordt College

How Did We Get Our Tax System? (And What Can That Teach Us About Reforming It?), Donald Roth

Faculty Work Comprehensive List

"In celebration of the 30th compliance year of the Internal Revenue Code, I’ve compiled three articles covering the past, present, and future of America’s tax system."

Posting about ­­­­­­­­the history of American taxation 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/how-did-we-get-our-tax-system-and-what-can-that-teach-us-about-reforming-it/


The Gordian Knot: How The United States, The European Union, And Organization For Economic Cooperation And Development Took Action Against Corporate Tax Avoidance, Katlyn Twomey 2017 Bryant University

The Gordian Knot: How The United States, The European Union, And Organization For Economic Cooperation And Development Took Action Against Corporate Tax Avoidance, Katlyn Twomey

Honors Projects in History and Social Sciences

In 2016, the United States had the highest corporate tax rate in the world. Perhaps, the high tax rate could be why American corporations are holding an estimated $2.5 trillion abroad (Cox 2016). According to a study by the Bureau of Economic Analysis, U.S. firms pay a measly 3% in tax to foreign governments on those profits, rather than the 35% U.S. corporate tax rate. How are these corporations able to legally avoid paying taxes on a large percentage of their profits? Many use various loopholes in the laws to shift profits into other countries or U ...


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