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411 On Fundraising For Charitable Organizations, Terri Helge Feb 2014

411 On Fundraising For Charitable Organizations, Terri Helge

Terri L. Helge

No abstract provided.


Revisiting The Tax Treatment Of Citizens Abroad: Reconciling Principle And Practice, Michael S. Kirsch Feb 2014

Revisiting The Tax Treatment Of Citizens Abroad: Reconciling Principle And Practice, Michael S. Kirsch

Michael Kirsch

In an increasingly mobile world, the taxation of citizens living abroad has taken on increased importance. Recent international administrative developments — most notably, the weakening of foreign bank secrecy and expansion of global information sharing norms — have further raised the profile of this issue. While U.S. law traditionally has taxed U.S. citizens living abroad in the same general manner as citizens living in the United States, a number of scholars have proposed abandoning the use of citizenship as a jurisdictional basis to tax. In its place, they would apply residence-based principles — i.e., exercising full taxing rights over U.S. …


Taxing Indirect Transfers: Improving An Instrument For Stemming Tax And Legal Base Erosion, Wei Cui Sep 2013

Taxing Indirect Transfers: Improving An Instrument For Stemming Tax And Legal Base Erosion, Wei Cui

Wei Cui

Numerous countries (e.g. Canada, Australia and Japan) tax foreigners on the gains realized on transfers of interests in foreign entities that invest directly or indirectly in real estates in these countries. In the last few years, actions taken by tax authorities in India, China, Brazil, Indonesia and other non-OECD countries have highlighted the possibility of taxing a broader range of “indirect share transfers” by foreigners. This Article argues taxing indirect transfers can have vital policy significance in countries where foreign inbound investments are actively traded in offshore markets: it not only deters tax avoidance, but may also stanch “legal base …


The Inefficiencies Of Legislative Centralization: Evidence From Chinese Provincial Tax Rate Setting, Wei Cui Dec 2012

The Inefficiencies Of Legislative Centralization: Evidence From Chinese Provincial Tax Rate Setting, Wei Cui

Wei Cui

Legislative power in China is centralized to an unusual degree, both in comparison to other countries and relative to the country’s high degree of administrative decentralization. Given its a priori inefficiencies, this arrangement should be significant from both positive and normative perspectives, but, surprisingly, has received little attention in legal and social scientific scholarship. We devise a novel method for analyzing the inefficiencies of centralization through studying provincial government behavior, examining provincial rate setting for the vehicle and vessel tax (VVT) in 2007 and 2011. Because all provinces have assigned VVT revenue and VVT administration to sub-provincial governments, provincial rate-setting …


Taxing Social Enterprise, Lloyd Hitoshi Mayer, Joseph R. Ganahl Dec 2012

Taxing Social Enterprise, Lloyd Hitoshi Mayer, Joseph R. Ganahl

Lloyd Hitoshi Mayer

The fairly strict divide in the United States between for-profit and nonprofit forms presents a quandary for many entrepreneurs who want to combine doing good with doing well. On the one hand, for-profits offer great flexibility and access to capital and so attract entrepreneurs who would like to take advantage of the ability of for-profits to scale up rapidly to meet growing demand. At the same time, however, for-profit forms also limit entrepreneurs’ ability to engage in philanthropy, due to the fiduciary duties managers owe to the equity holders. On the other hand, nonprofits offer their founders the freedom to …


Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault Dec 2012

Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault

Hugh J. Ault

No abstract provided.


Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault Sep 2012

Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault

Hugh J. Ault

No abstract provided.


Nuts And Bolts Of Unrelated Business Income Tax, Terri Helge Aug 2012

Nuts And Bolts Of Unrelated Business Income Tax, Terri Helge

Terri L. Helge

No abstract provided.


Reforming The Private Benefit Doctrine, Terri Helge Jun 2012

Reforming The Private Benefit Doctrine, Terri Helge

Terri L. Helge

No abstract provided.


Limited Liability Entities: State By State Guide To Llcs, Llps And Lps, Bradley Borden, Robert Rhee May 2012

Limited Liability Entities: State By State Guide To Llcs, Llps And Lps, Bradley Borden, Robert Rhee

Robert Rhee

To make your research more efficient Wolters Kluwer Law & Business is combining the former State Limited Liability Company and Partnership Laws and State Limited Partnership Laws title into one new resource entitled Limited Liability Entities: State by State Guide to LLCs, LLPs and LPs. Our new authors are Bradley Borden and Robert Rhee (see About the Authors). Volume 1, the first installment of Limited Liability Entities: State by State Guide to LLCs, LLPs and LPs, provides a comprehensive overview of limited liability entities. It begins with a detailed review of the history and evolution of limited liability entities. It …


U.S. Taxes Corporate Income At Comparatively Low Rate, Andrew Pike Mar 2012

U.S. Taxes Corporate Income At Comparatively Low Rate, Andrew Pike

Andrew Pike

This article asserts that the United States does not subject corporate profits to a relatively high nominal rate of taxation. In support of this assertion, the article analyzes the VAT, and concludes that the VAT incorporates a tax on corporate profits. The portion of the VAT that taxes corporate profit is comparable to, and at least as burdensome as, the current U.S. corporate income tax. The article concludes that the accepted wisdom that the United States imposes an exceptionally high nominal rate of tax (compared to the nominal rates of taxation imposed in other OECD countries) on corporate profits is …


Giving Strategies In The New Tax Climate, Terri Helge Feb 2012

Giving Strategies In The New Tax Climate, Terri Helge

Terri L. Helge

No abstract provided.


Tax & Legislative Update: Recent Developments In Charitable Giving, Terri Helge Feb 2012

Tax & Legislative Update: Recent Developments In Charitable Giving, Terri Helge

Terri L. Helge

No abstract provided.


Public Charities: A Practical Guide To Key Issues, Choices And Risks, Terri Helge Jan 2012

Public Charities: A Practical Guide To Key Issues, Choices And Risks, Terri Helge

Terri L. Helge

No abstract provided.


Overview Of Nonprofit Organizations: The Basic Framework, Terri Helge Jan 2012

Overview Of Nonprofit Organizations: The Basic Framework, Terri Helge

Terri L. Helge

No abstract provided.


Interviewed - Cause & Effect, Terri Helge Dec 2011

Interviewed - Cause & Effect, Terri Helge

Terri L. Helge

No abstract provided.


Innovation And Constraints On Tax Shelters, Jessica Howell O'Neill Dec 2011

Innovation And Constraints On Tax Shelters, Jessica Howell O'Neill

Jessica Howell O'Neill

No abstract provided.


Charitable Donations: Giving To Museums And Nonprofits, Terri Helge Feb 2011

Charitable Donations: Giving To Museums And Nonprofits, Terri Helge

Terri L. Helge

No abstract provided.


How New Custody Rule Impacts Cpa Financial Planners, William Byrnes Jan 2011

How New Custody Rule Impacts Cpa Financial Planners, William Byrnes

William H. Byrnes

No abstract provided.


An Empirical Survey Of The Population Of U.S. Tax Court Written Decisions, Daniel Katz, M Bommarito, J Isaacs-See Dec 2010

An Empirical Survey Of The Population Of U.S. Tax Court Written Decisions, Daniel Katz, M Bommarito, J Isaacs-See

Daniel M Katz

No abstract provided.


Fiscal Federalism In Chinese Taxation, Wei Cui Dec 2010

Fiscal Federalism In Chinese Taxation, Wei Cui

Wei Cui

The legal debate about the decentralization of taxing power in China has mainly centered around a directive issued by the State Council at the end of 1993, which directive, at the same time as launching the well-known and widely-discussed tax reform of 1994, announced that legislative power regarding taxation would be reserved exclusively for the central government. This directive has no constitutional basis, and its subsequent statutory incarnations are all either incomplete or ambiguous. Moreover, in the adoption of tax regulations for many types of taxes, there have been numerous deviations from this principle of centralization, and the bearing of …


Panelist, Oecd Conference On Intangibles, Hugh Ault Nov 2010

Panelist, Oecd Conference On Intangibles, Hugh Ault

Hugh J. Ault

No abstract provided.


Understand How The Obama Tax Reforms Will Impact Your Organization, Terri Helge Sep 2010

Understand How The Obama Tax Reforms Will Impact Your Organization, Terri Helge

Terri L. Helge

No abstract provided.


Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault Jul 2010

Panelist, Max Planck Insitute For Taxation Advisory Board, Hugh Ault

Hugh J. Ault

No abstract provided.


Transfer Pricing, Hugh Ault Jul 2010

Transfer Pricing, Hugh Ault

Hugh J. Ault

Chaired meeting of 45 governmental and academic specialist


Recent Treaty Developments In The Arbitration Of International Tax Disputes, Hugh Ault Dec 2009

Recent Treaty Developments In The Arbitration Of International Tax Disputes, Hugh Ault

Hugh J. Ault

No abstract provided.


Aall Academic Law Library Special Interest Section’S Task Force On The Aba Standards Review, Gordon Russell Nov 2009

Aall Academic Law Library Special Interest Section’S Task Force On The Aba Standards Review, Gordon Russell

Gordon R. Russell

No abstract provided.


Panelist, The International Network For Tax Research And The American Journal Of Comparative, Conference On "Comparative Tax Law: Theory And Practice, Hugh Ault Sep 2009

Panelist, The International Network For Tax Research And The American Journal Of Comparative, Conference On "Comparative Tax Law: Theory And Practice, Hugh Ault

Hugh J. Ault

No abstract provided.


Award Presentation: 63rd International Fiscal Association Annual Meeting, Hugh Ault Aug 2009

Award Presentation: 63rd International Fiscal Association Annual Meeting, Hugh Ault

Hugh J. Ault

No abstract provided.


Panelist, Confederation Of Swedish Enterprise, Tax Aspects Of Tradable Emissions Permits, Hugh Ault May 2009

Panelist, Confederation Of Swedish Enterprise, Tax Aspects Of Tradable Emissions Permits, Hugh Ault

Hugh J. Ault

No abstract provided.