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Articles 1 - 11 of 11
Full-Text Articles in Law
Legislative Foundation Of The United States' New International Tax System, Joshua D. Harms
Legislative Foundation Of The United States' New International Tax System, Joshua D. Harms
Seattle University Law Review
This Note begins with commentary on the United States’ former worldwide system of taxation. This system taxed multinational corporations’ offshore profits at the applicable domestic income tax rate less credits for taxes paid to foreign governments. This tax regime provided for the deferral of income tax due on the profits of multinational corporations’ overseas operations until the time of repatriation. This Note considers the issues inherent in this system and analyzes the repatriation tax holiday under the American Jobs Creation Act of 2004. This holiday has been unanimously criticized by both sides of the political aisle and led to large …
Increasing Investor Protection Through Improving Hedge Fund Valuation, Deirdre Farrell
Increasing Investor Protection Through Improving Hedge Fund Valuation, Deirdre Farrell
St. John's Law Review
(Excerpt)
This Note examines the current hedge fund regulations in the United States and in Europe, and proposes ways for regulators to improve hedge fund valuation in the United States to increase investor protection. Although valuation issues affect all pooled investment vehicles that invest in illiquid, difficult-to-value assets, this Note focuses only on the valuation systems of hedge funds.
Part I gives an overview of hedge funds in general—their structure and the major stakeholders involved. Part II summarizes the valuation process and its associated issues. Part III describes recent regulatory changes in the United States affecting hedge funds, including the …
De Novo: Reviewing Tax Court Redressability Incongruities In Innocent Spouse Relief Sections 66© And 6015(F), Jason Harn
De Novo: Reviewing Tax Court Redressability Incongruities In Innocent Spouse Relief Sections 66© And 6015(F), Jason Harn
Seattle University Law Review
Part One of this Note details the historical background of joint and several liability in federal income taxation. Part Two introduces, compares, and contrasts the two statutory provisions Congress has enacted to relieve “innocent spouses” from joint and several liability. Part Three discusses the incongruent standards of review applied by the Tax Court to these—§§ 66 and 6015—two substantially similar relief provisions. Finally, Part Four suggests remedies to alleviate this incongruity.
California Board Of Accountancy, Anna V. Randall, J. D. Fellmeth
California Board Of Accountancy, Anna V. Randall, J. D. Fellmeth
California Regulatory Law Reporter
No abstract provided.
Sourcing Service Receipts For Franchise Tax Apportionment In Texas, Ray Langenberg, Matt Jones
Sourcing Service Receipts For Franchise Tax Apportionment In Texas, Ray Langenberg, Matt Jones
St. Mary's Law Journal
Abstract forthcoming
The Cfpb’S Endaround, Chris O'Brien
The Cfpb’S Endaround, Chris O'Brien
Catholic University Law Review
The financial crisis of 2008 led Congress to enact the Dodd-Frank Wall Street Reform and Consumer Protection Act and establish the Consumer Financial Protection Bureau (CFPB) to better protect consumers. Although Dodd-Frank and the CFPB introduced sweeping changes to many areas of financial lending, automobile dealers and financers were expressly excluded from oversight by the CFPB. Despite this express limitation on the CFPB’s authority, the Bureau nonetheless expanded its definition of “larger participants” to encompass automobile dealers and financiers. This action has resulted in duplicative regulatory oversight and increased costs to consumers, which in turn, imposes additional burdens on those …
Accessible Reliable Tax Advice, Emily Cauble
Accessible Reliable Tax Advice, Emily Cauble
University of Michigan Journal of Law Reform
Unsophisticated taxpayers who lack financial resources are disadvantaged by a shortage of adequate tax advice. The IRS does not have the resources to answer all questions asked, and the IRS’s informal advice comes with no guarantee as to its accuracy and offers the taxpayer no protection when it is mistaken. Furthermore, non-IRS sources of advice have not sufficiently filled the void left by a lack of satisfactory IRS guidance. These biases against unsophisticated taxpayers have been noted by existing literature. This Article contributes to existing literature by proposing several novel reform measures to assist unsophisticated taxpayers.
First, with respect to …
How Special Is The Special Timing Rule? Analyzing The Timing Of Fica Taxation In Nonqualified Deferred Compensation Plans, Alan J. Ponce
How Special Is The Special Timing Rule? Analyzing The Timing Of Fica Taxation In Nonqualified Deferred Compensation Plans, Alan J. Ponce
Georgia State University Law Review
Many employers offer nonqualified deferred compensation plans as a benefit to select employees, and those plans allow the employees to prepare for retirement in a tax-efficient manner. For employers,designing and administering such plans in compliance with federal law represents a paramount concern in order to achieve the tax advantages such plans entail. However, for these employers, there remains an inherent ambiguity in the tax code regarding how and when employers should withhold Federal Insurance Contribution Act (FICA) taxes—that is, Social Security and Medicare taxes—on deferred compensation in nonqualified retirement plans.
Tax regulations provide two distinct methods for withholding FICA taxes …
Tax Compliance In A Decentralizing Economy, Manoj Viswanathan
Tax Compliance In A Decentralizing Economy, Manoj Viswanathan
Georgia State University Law Review
Tax compliance in the United States has long relied on information from centralized intermediaries—the financial institutions,employers, and brokers that help ensure income is reported and taxes are paid. Yet while the IRS remains tied to these centralized entities,consumers and businesses are not. New technologies, such as sharing economy platforms (companies such as Airbnb, Uber, and Instacart)and the blockchain (the platform on which various cryptocurrencies are based) are providing new, decentralized options for exchanging goods and services.
Without legislative and agency intervention, these technologies pose a critical threat to the reporting system underlying domestic and international tax compliance. Until now, legal …
Getting Local Governments Where They Need To Go Without Taking Taxpayers For A Ride: "Cabs," Why They Are Used, And What Can Be Done To Prevent Their Misuse, Heather G. White
Getting Local Governments Where They Need To Go Without Taking Taxpayers For A Ride: "Cabs," Why They Are Used, And What Can Be Done To Prevent Their Misuse, Heather G. White
St. Mary's Law Journal
Abstract forthcoming
The Future Of The New International Tax Regime, Rosanne Altshuler, Fadi Shaheen, Jeffrey Colon, Michael Graetz, Rebecca Kysar, Susan Morse, Daniel Shaviro, Richard Phillips, Danielle Rolfes, David Rosenbloom, Stephen Shay, Steven Dean
The Future Of The New International Tax Regime, Rosanne Altshuler, Fadi Shaheen, Jeffrey Colon, Michael Graetz, Rebecca Kysar, Susan Morse, Daniel Shaviro, Richard Phillips, Danielle Rolfes, David Rosenbloom, Stephen Shay, Steven Dean
Fordham Journal of Corporate & Financial Law
No abstract provided.