Open Access. Powered by Scholars. Published by Universities.®

Taxation-Federal Commons

Open Access. Powered by Scholars. Published by Universities.®

1960 Full-Text Articles 1023 Authors 639514 Downloads 78 Institutions

All Articles in Taxation-Federal

Faceted Search

1960 full-text articles. Page 6 of 44.

Embracing The Queen Of Hearts: Deference To Retroactive Tax Rules, James M. Puckett 2016 Penn State Law

Embracing The Queen Of Hearts: Deference To Retroactive Tax Rules, James M. Puckett

James Puckett

The Supreme Court’s decision in Mayo Foundation for Medical Education and Research v. United States underscored the importance of a uniform approach to judicial review of administrative action; accordingly, the Court clarified that tax administration is generally subject to the same review as other kinds of administrative action by other federal agencies. Tax guidance from the IRS and Treasury Department serves an important role in clarifying the tax law so that taxpayers may report their tax liability accurately and plan their affairs. Meanwhile, aggressive attempts by a relatively small number of taxpayers to avoid tax liability by exploiting arguable ...


Registered Savings Plans And The Making Of Middle Class Canada: Toward A Performative Theory Of Tax Policy, Lisa Philipps 2016 Osgoode Hall Law School of York University

Registered Savings Plans And The Making Of Middle Class Canada: Toward A Performative Theory Of Tax Policy, Lisa Philipps

Articles & Book Chapters

Politicians across Canada’s political spectrum strive to position themselves as defenders of the middle class, and tax policy is a prime vehicle for making this pitch. Any tax reform proposal can be examined critically to evaluate its likely distributional impacts and how well these map onto specific definitions of the middle class. This article attempts, however, a different project. Drawing on the ideas of Judith Butler, it analyzes instead how tax policy produces middle-class identity through the very process of claiming to advance middle-class interests. The case study for this purpose is the rise of tax incentives for saving ...


Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd 2016 University of Georgia School of Law

Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd

Georgia Journal of International & Comparative Law

No abstract provided.


The Timing Of Tax Transparency, Joshua D. Blank 2016 NYU School of Law

The Timing Of Tax Transparency, Joshua D. Blank

New York University Law and Economics Working Papers

Fairness in the administration of the tax law is the subject of intense debate in the United States. As recent headlines reveal, the Internal Revenue Service has been accused of failing to enforce the tax law equitably in its review of tax-exempt status applications by political organizations, the international tax structures of multinational corporations, and the estate tax returns of millionaires, among other areas. Many have argued that greater “tax transparency” would better empower the public to hold the IRS accountable and the IRS to defend itself against accusations of malfeasance. Mandatory public disclosure of taxpayers’ tax return information is ...


Simplexity: Plain Language And The Tax Law, Joshua D. Blank, Leigh Osofsky 2016 NYU School of Law

Simplexity: Plain Language And The Tax Law, Joshua D. Blank, Leigh Osofsky

New York University Law and Economics Working Papers

In recent years, federal government agencies have increasingly attempted to use plain language in written communications with the public. The Plain Writing Act of 2010, for instance, requires agencies to incorporate “clear and simple” explanations of rules and regulations into their official publications. In the tax context, as part of its “customer service” mission, the Internal Revenue Service bears a “duty to explain” the tax law to hundreds of millions of taxpayers who file tax returns each year. Proponents of the plain language movement have heralded this form of communication as leading to simplicity in tax compliance, more equitable access ...


Transfer Pricing Challenges In The Cloud, Orly Mazur 2016 Southern Methodist University Dedman School of Law

Transfer Pricing Challenges In The Cloud, Orly Mazur

Boston College Law Review

Cloud computing has fundamentally changed how companies operate. Companies have quickly adapted by moving their businesses to the cloud, but international tax standards have failed to follow suit. As a result, taxpayers and tax administrations confront significant tax challenges in applying outdated tax principles to this new environment. One particular area that raises perplexing tax issues is the transfer pricing rules. The transfer pricing rules set forth the intercompany price a cloud service provider must charge an affiliate using its cloud services, which ultimately affects the determination of the jurisdiction in which the company’s profits are taxed. This Article ...


Bringing Continuity To Cryptocurrency: Commercial Law As A Guide To The Asset Categorization Of Bitcoin, Evan Hewitt 2016 Seattle University School of Law

Bringing Continuity To Cryptocurrency: Commercial Law As A Guide To The Asset Categorization Of Bitcoin, Evan Hewitt

Seattle University Law Review

This Note will undertake to analyze bitcoin under the Uniform Commercial Code (UCC) and the Internal Revenue Code (IRC)—two important sources of commercial law—to see whether any existing asset categories adequately protect bitcoin’s commercial viability. This Note will demonstrate that although commercial law dictates that bitcoin should—nay must—be regulated as a currency in order to sustain its existence, the very definition of currency seems to preclude that from happening. Therefore, this Note will recommend that we experiment with a new type of asset that receives currency-like treatment, specifically designed for cryptocurrencies, under which bitcoin can ...


Special Economic Zones In The United States: From Colonial Charters, To Foreign-Trade Zones, Toward Ussezs, Tom W. Bell 2016 Chapman University, Fowler School of Law

Special Economic Zones In The United States: From Colonial Charters, To Foreign-Trade Zones, Toward Ussezs, Tom W. Bell

Tom W. Bell

Special economic zones (SEZs) and the United States have a long and complicated relationship. The lineage of the United States runs back to proto-SEZs, created when Old World governments sold entrepreneurs charters to build for-profit colonies in the New World, such as Jamestown and New Amsterdam. In more recent times, though, the United States has lagged behind the rest of the world in tapping the potential of SEZs, which have exploded in number, types, territory, and population. True, the US hosts a large and growing number of Foreign-Trade Zones (FTZs), but these do little more than exempt select companies from ...


The Meaning Of Capital In The Twenty-First Century, Edward J. McCaffery 2016 University of Southern California;California Institute of Tecnology

The Meaning Of Capital In The Twenty-First Century, Edward J. Mccaffery

University of Southern California Legal Studies Working Paper Series

America is on a path towards a level of both wealth and income inequality unparalleled in recorded history. Thomas Piketty’s Capital in the Twenty-First Century summarizes and conveys the work of Piketty and many co-authors, over many decades, looking at the structure of income and wealth inequality across many nations and centuries. This review essay builds on Piketty’s ambitions as well as his data, in order to put forth a better solution: one that accepts and even embraces the facts of unequal ownership of capital, but changes the social meaning of those facts to avoid the social harms ...


The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016, 2016 San Jose State University

The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016

The Contemporary Tax Journal

No abstract provided.


The Altera Case: Tax Ramifications Of Stock-Based Compensation, Sandhya Dharani 2016 San Jose State University

The Altera Case: Tax Ramifications Of Stock-Based Compensation, Sandhya Dharani

The Contemporary Tax Journal

No abstract provided.


When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh 2016 San Jose State University

When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh

The Contemporary Tax Journal

No abstract provided.


Front Matter (Letter From The Editor, Masthead, Etc.), 2016 San Jose State University

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

The Contemporary Tax Journal

No abstract provided.


Repeal The Alternative Minimum Tax, Branden Wilson 2016 San Jose State University

Repeal The Alternative Minimum Tax, Branden Wilson

The Contemporary Tax Journal

No abstract provided.


Cloud Activities And Issues Under Irc Sections 41 And 199, Marina Pinato 2016 San Jose State University

Cloud Activities And Issues Under Irc Sections 41 And 199, Marina Pinato

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal’S Interview Of Eli Dicker, Shruti Raja 2016 San Jose State University

The Contemporary Tax Journal’S Interview Of Eli Dicker, Shruti Raja

The Contemporary Tax Journal

No abstract provided.


Consolidation Of Educational Tax Credits, Michael Hynson 2016 San Jose State University

Consolidation Of Educational Tax Credits, Michael Hynson

The Contemporary Tax Journal

No abstract provided.


To Win Or Not To Win! Article On Prize And Awards, Shilpa Balnadu 2016 San Jose State University

To Win Or Not To Win! Article On Prize And Awards, Shilpa Balnadu

The Contemporary Tax Journal

No abstract provided.


Irs Developments And Examination Strategies, Aaron Grey 2016 San Jose State University

Irs Developments And Examination Strategies, Aaron Grey

The Contemporary Tax Journal

No abstract provided.


A Panel Discussion Of Recent Developments In State Tax Reform, Leonel Renteria 2016 San Jose State University

A Panel Discussion Of Recent Developments In State Tax Reform, Leonel Renteria

The Contemporary Tax Journal

No abstract provided.


Digital Commons powered by bepress