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Ancillary Joint Ventures And The Unanswered Questions After Revenue Ruling 2004-51
Ancillary Joint Ventures And The Unanswered Questions After Revenue Ruling 2004-51
Gabriel O Aitsebaomo
Ever since the Internal Revenue Service (the "Service") issued Revenue Ruling 98-15… in which it emphasized "control" as a critical factor in determining whether a tax-exempt hospital that enters into a whole-hospital joint venture with a for-profit entity would continue to maintain its tax-exemption, practitioners and scholars alike have sought guidance from the Service regarding whether such "control" would also be required of an exempt organization that enters into an "ancillary joint venture" with a for-profit entity. In response, the Service issued Revenue Ruling 2004-51 on May 6, 2004.
… In Revenue Ruling 2004-51, the Service enunciated that a tax-exempt …
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Tax Competition: What (If Anything) To Do About It?, Hugh Ault
Hugh J. Ault
No abstract provided.
Federal Income Taxation: Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation: Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 2000 Supplement: Federal Income Taxation: Cases and Materials, 4th ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 2000; 2003 Supplement: Federal Income Taxation: Cases and Materials, 4th ed., by McDaniel, Ault, McMahon and Simmons. New York: Foundation Press, 2003
The Oecd's Report On Harmful Tax Competition, Hugh Ault, Joann Weiner
The Oecd's Report On Harmful Tax Competition, Hugh Ault, Joann Weiner
Hugh J. Ault
In response to pressures created by the increasing globalization of the world economy, the OECD has issued a report titled “Harmful Tax Competition: An Emerging Global Issue” that provides an analysis of the phenomenon known as harmful tax competition. The Report identifies factors that characterize tax havens and harmful preferential tax regimes and recommends numerous measures in the areas of domestic legislation, tax treaties, and international cooperation, that countries may pursue to counter harmful tax competition. As part of intensifying international cooperation, the Report recommends that Member countries adopt a set of Guidelines endorsing the “3 R’s:” to refrain, to …
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Introduction To United States International Taxation, Hugh Ault, Paul Mcdaniel
Hugh J. Ault
No abstract provided.
The Use Of Tax Law To Stabilize The Stock Market: The Efficacy Of Holding Period Requirements, James R. Repetti
The Use Of Tax Law To Stabilize The Stock Market: The Efficacy Of Holding Period Requirements, James R. Repetti
James R. Repetti
No abstract provided.
The Reagan Tax Plan Viewed Internationally, Hugh Ault, Alan Granwell, Philip Kaplan
The Reagan Tax Plan Viewed Internationally, Hugh Ault, Alan Granwell, Philip Kaplan
Hugh J. Ault
No abstract provided.