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Full-Text Articles in Business

Burgers, Doughnuts, And Expatriations: An Analysis Of The Tax Inversion Epidemic And A Solution Presented Through The Lens Of The Burger King-Tim Hortons Merger, Chris Capurso Mar 2016

Burgers, Doughnuts, And Expatriations: An Analysis Of The Tax Inversion Epidemic And A Solution Presented Through The Lens Of The Burger King-Tim Hortons Merger, Chris Capurso

William & Mary Business Law Review

Currently, the concept of tax inversion is a major corporate phenomenon. In the United States, companies pay taxes on all earnings, whether or not they were accumulated here. With one of the highest corporate tax rates in the world, this is a major expense for U.S. corporations competing in the world market. While most companies simply deal with the tax burden, some U.S. corporations buy foreign companies and relocate the company headquarters to the acquisition’s home country. This corporate expatriation allows companies to avoid U.S. taxes on earnings in a number of ways. This Note will examine tax inversion through …


Tax Tarp Needed For Year One And Year Two Returns Of Executive Bonus To Tarp Recipient: A Case Study Of Year One Rescission/Exclusion From Income And Year Two Deduction Under Section 1341, John W. Lee Apr 2010

Tax Tarp Needed For Year One And Year Two Returns Of Executive Bonus To Tarp Recipient: A Case Study Of Year One Rescission/Exclusion From Income And Year Two Deduction Under Section 1341, John W. Lee

William & Mary Business Law Review

This Article addresses the tax consequences to AIG Financial employees who repay their controversial retention bonuses in the year of receipt (Year 1) or in a subsequent year (Year 2). At the time the executives received their bonuses, the media and members of Congress raised challenges that might induce such repayment, thus justifying favorable tax treatment for repaying executives. Accordingly, bonuses repaid in year I should be excluded from gross income under the doctrine of Year 1 rescission. Bonuses repaid in Year 2 should result in an adjustment under Section 1341, which reduces the income taxes for Year 2 by …


The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott Oct 1970

The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott

William & Mary Law Review

No abstract provided.


The Influence Of Disallowed Preacquisition Losses On The Recognition Of Postacquisition Losses Under Section 269, Homer L. Elliott Oct 1968

The Influence Of Disallowed Preacquisition Losses On The Recognition Of Postacquisition Losses Under Section 269, Homer L. Elliott

William & Mary Law Review

No abstract provided.