Taxation Commons^™

Ultras: Rethinking Tax Policy For Digital Assets, Lauren Liedel

The Journal of Business, Entrepreneurship & the Law

This comment examines the challenges current federal tax policy faces in addressing the rapidly expanding and volatile digital asset market. The author argues that the Internal Revenue Service’s (IRS) current "piecemeal" approach to defining taxable events—such as mining and staking—creates significant uncertainty for taxpayers and leads to strategic litigation. To resolve these issues, the article proposes the adoption of Unliquidated Tax Reserve Accounts (ULTRAs) as an alternative reporting framework. By utilizing blockchain's inherent capability to track notional interests, ULTRAs allow the IRS to account for economic activity while offering taxpayers the flexibility to defer actual payment until the assets are …

Relevance Matters After Patel: Where The Economic Substance Doctrine Goes From Here, Daniel Chung

The Journal of Business, Entrepreneurship & the Law

This article examines the modern Economic Substance Doctrine (ESD) through the framework of the Tax Court's decision in Patel v. Commissioner. The author argues that Patel serves as a "doctrinal reset," restoring the ESD to its intended role as a narrow, purpose-driven judicial backstop rather than a generalized anti-abuse tool. Central to this analysis is the reemergence of a "relevance" inquiry, which requires courts to determine if the ESD applies to a transaction at all—based on pre-codification common law—before engaging the statutory two-prong test under Section 7701(o) . While the court in Patel ultimately found the doctrine relevant and sustained …

Your Money, Your Message, Ella Rosebrook

Honors Projects

The Your Money, Your Message pamphlet offers a basic overview of personal finance and personal branding to act as a guide for young adults looking to further their knowledge in these areas. It gives beginner-level guidance in budgeting, tracking spending and saving habits, filing taxes with a CPA, a brief description of common payroll taxes, and personal branding. It is important for individuals entering the workforce to be knowledgeable in these areas no matter what their major is, as these skills will bring about a positive impact for anyone. Developing healthy personal finance habits and a strong personal brand is …

Entrepreneurial Orientation And Performance Of Microfinance Cooperatives: Evidence From Tanzania, Grace Thomas Mori, Omari Khalifa Mbura

Business Management Review

Microfinance cooperatives (MFCs) play a key role in socio-economic development, predominantly in developing countries. However, studies focusing on the relationship between entrepreneurial orientation (EO) and the performance of MFCs are limited, particularly in Tanzania. This study was informed by the resource-based view to examine the influence of EO dimensions on the performance of MFCs in Tanzania. Specifically, the study focused on four dimensions of EO namely; innovativeness, proactiveness, risk taking, and competitive aggressiveness behaviours. Data were obtained from 299 stratified sampled managers of MFCs through the administration of a structured questionnaire. In testing this relationship, Partial Least Squares Structural Equation …

The Price Of Democracy: The Revolutionary Power Of Taxation In American History, Vanessa Williamson

Brookings Scholar Lecture Series

As part of the Brookings Scholar Lecture Series, Brookings Mountain West presented a lecture titled, "The Price of Democracy: The Revolutionary Power of Taxation in American History" by Brookings senior fellow in governance studies, Vanessa Williamson.

From tariffs to “no tax on tips”, taxation has often been a hot topic in American elections. What is not commonly recognized, however, is that—from the framing of the Constitution to the decades-long backlash to the civil rights movement—taxes have been at the heart of battles over the breadth of our democracy. Brookings senior fellow Vanessa Williamson discusses her new book, The Price of …

The Contemporary Tax Journal’S Interview Of Taylor Reid, Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025:Ai And Other Emerging Technologies For Tax Practitioners, Raymond Clark

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025:Corporate Amt, Weng (Gary) Ng

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025: The Latest And Greatest In M & A And Other Transactional Tax Developments, Agnes Yip

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025: Hot Topics In Accounting For Income Taxes, Jing Luo

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025: Building A Relationship With The Board Of Directors, Jasleen Hothi

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025: Research And Development Credits, Cases, Tcja.2 And More, Dale Loepp

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025: Controversy And Guidance In A Constrained And Restricted Environment, Leah Upson

The Contemporary Tax Journal

No abstract provided.

The Third Annual Blockchain Tax Conference On January 30, 2026: Dealing With The 2025 Forms 1099-Da, Leah Upson

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal Volume 14, No. 2 – Winter 2026

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4 ,2025: Domestic And Multistate Update, Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025:International High Technology U.S. Tax Current Developments, Sviatlana Yakavets

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025: Tariffs, Transfer Pricing, §1059a, Customs, Retaliation And More, Mya Hoang

The Contemporary Tax Journal

No abstract provided.

The 41st Annual Tei – Sjsu High Tech Tax Institute Conference On November 3-4, 2025: Tax Issues In International Ip Transactions, Sandhya Dharani

The Contemporary Tax Journal

No abstract provided.

Ownership Structure And Corporate Tax Avoidance In Malaysia: The Moderating Role Of Multinational Corporation Status, Tan Shu Qi

Student Works (2020-2029)

This study examines the relationship between ownership structure and corporate tax avoidance among Malaysian publicly listed firms, with particular emphasis on the moderating role of multinational corporation (MNC) status. Drawing on agency theory, the study investigates how three ownership types government ownership, managerial ownership, and institutional ownership influence firms’ tax avoidance behaviour. Using a quantitative research design, the study analyses panel data from 885 non-financial companies listed on Bursa Malaysia’s Main Market over the post-COVID-19 period from 2021 to 2023. Tax avoidance is proxied using adjusted effective tax rates (ETRadjusted), and panel regression techniques are employed to test the hypothesised …