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Tax Law

Selected Works

2010

Articles 1 - 24 of 24

Full-Text Articles in Law

Third Party Access And Refusal To Deal In European Energy Networks: How Sector Regulation And Competition Law Meet Each Other, Michael Diathesopoulos Dec 2010

Third Party Access And Refusal To Deal In European Energy Networks: How Sector Regulation And Competition Law Meet Each Other, Michael Diathesopoulos

Michael Diathesopoulos

In this paper, we will analyse the issue of concurrence between competition and sector rules and the relation between parallel concepts within the two different legal frameworks. We will firstly examine Third Party Access in relation to essential facilities doctrine and refusal of access and we will identify the common points and objectives of these concepts and the extent to which they provide a context to each other’s implementation. Second, we will focus on how Commission uses sector regulation and objectives as a context within the process of implementation of competition law in the energy sector and third, we will …

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The Behavior Of Justice Douglas In Federal Tax Cases, Marjorie A. Silver, Bernard Wolfman, Jonathan L. F. Silver Dec 2010

The Behavior Of Justice Douglas In Federal Tax Cases, Marjorie A. Silver, Bernard Wolfman, Jonathan L. F. Silver

Marjorie A. Silver

No abstract provided.

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Secret Bancaire Et Entraide Internationale En Matière Fiscale: Le Fait Du Prince, Fabien Liegeois Nov 2010

Secret Bancaire Et Entraide Internationale En Matière Fiscale: Le Fait Du Prince, Fabien Liegeois

Dr. Fabien LIEGEOIS

No abstract provided.

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Panelist, Oecd Conference On Intangibles, Hugh Ault Nov 2010

Panelist, Oecd Conference On Intangibles, Hugh Ault

Hugh J. Ault

No abstract provided.

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Llm Cyberlaw: Information Technology, Law And Society, Subhajit Basu Oct 2010

Llm Cyberlaw: Information Technology, Law And Society, Subhajit Basu

Subhajit Basu

LLM in Cyberlaw: information technology, law and society enables you to develop knowledge and skills in relation to the legal rules regulating cyberlaw activity in the UK and Europe, and at a global level.

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What Tax Lawyers Need To Know Before Choosing A Forum For Their Next Federal Civil Tax Litigation Dispute, Robert D. Probasco Oct 2010

What Tax Lawyers Need To Know Before Choosing A Forum For Their Next Federal Civil Tax Litigation Dispute, Robert D. Probasco

Robert Probasco

No abstract provided.

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Quoted In Bna Daily Tax Report On Uncertain Tax Positions Guidance, Robert D. Probasco Oct 2010

Quoted In Bna Daily Tax Report On Uncertain Tax Positions Guidance, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposed Amendments To Treasury Circular 230, Robert D. Probasco, David Colmenero, Mandi L. Matlock Oct 2010

Comments On Proposed Amendments To Treasury Circular 230, Robert D. Probasco, David Colmenero, Mandi L. Matlock

Robert Probasco

The vast majority of federal individual income tax return s are prepared by paid tax return preparers or by taxpayers using consumer tax preparation software. Circular 230 governs practice before the Service by attorneys, certified public accountants, enrolled agents, enrolled actuaries, and enrolled retirement plan agents (collectively, "practitioners" ). Circular 230, however, has not applied to paid tax return preparers who did not fall within any of the categories of practitioners. Various observers, including the National Taxpayer Advocate and consumer advocacy groups, have expressed significant concerns about the lack of regulation of such unenrolled tax return preparers. 1n June 2009, …

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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.

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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.

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Transfer Pricing, Hugh Ault Jul 2010

Transfer Pricing, Hugh Ault

Hugh J. Ault

Chaired meeting of 45 governmental and academic specialist

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Federal Tax Update, Robert D. Probasco Jun 2010

Federal Tax Update, Robert D. Probasco

Robert Probasco

No abstract provided.

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Comments On Proposal Regarding Uncertain Tax Positions, Robert D. Probasco, Bruce Bernstien, Mark Horowitz May 2010

Comments On Proposal Regarding Uncertain Tax Positions, Robert D. Probasco, Bruce Bernstien, Mark Horowitz

Robert Probasco

These comments are presented on behalf of the Section of Taxation of the State Bar of Texas. The principal drafters of these comments were Robert D. Probasco, Mark Horowitz and Bruce Bemstien. Additional contributors were Val J. Albright, David E. Colmenero, Joel N. Crouch, Brian Dethrow, Kenneth M. Horwitz and Ronald D. Kerridge. The Committee on Government Submissions (COGS) of the Section of Taxation of the State Bar of Texas has approved these comments. Daniel G. Baucum is the Chair of COGS, and Emily Parker and Daniel J. Micciche reviewed the comments on behalf of COGS.

The following comments are …

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In Whom We Trust, Temple K. Fogg Jan 2010

In Whom We Trust, Temple K. Fogg

T. Keith Fogg

The Internal Revenue Service ("IRS") collects the majority of taxes through business entities that are required to withhold taxes from wages or collect excise taxes at the time of providing services. These business entities hold the taxes they collect in trust for the IRS. The wast majority of business entities pay over the taxes held in trust in a timely and appropriate manner; however, a sizeable amount, in dollar terms, does not get paid. Aside from passing criminal laws at or near the passage of the 1954 code, Congress has done little to create a structure that provides incentives for …

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Collaborative Experience: Cataloging Projects With Cassidy Cataloging, Gordon R. Russell, Paula Tejeda, Joni L. Cassidy Jan 2010

Collaborative Experience: Cataloging Projects With Cassidy Cataloging, Gordon R. Russell, Paula Tejeda, Joni L. Cassidy

Gordon R. Russell

No abstract provided.

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Legislation And Other Hot Topics, Jonathan B. Forman Jan 2010

Legislation And Other Hot Topics, Jonathan B. Forman

Jonathan B. Forman

No abstract provided.

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Taxation: Law, Planning, And Policy, David Gamage, Michael Livingston Dec 2009

Taxation: Law, Planning, And Policy, David Gamage, Michael Livingston

David Gamage

This is a sample version of the Introduction, Table of Contents, Background and Basic Themes section, and first chapter, from the second edition of the casebook "Taxation: Law, Planning, and Policy". This sample is posted with the permission of LexisNexis publishing for review purposes by students and instructors.

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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.

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The Economy Of Undocumented Migration: Taxation And Access To Welfare, Mats Tjernberg Dec 2009

The Economy Of Undocumented Migration: Taxation And Access To Welfare, Mats Tjernberg

Mats Tjernberg

A strict division between the formal economy and the informal economy cannot be made and every economic actor has in certain situations a propensity to engage in informal economic activities. The formal, as well as informal, economy may lead to economic growth which is essential for a broad welfare policy, under which social benefits are categorized. A person’s economic contribution to a state should entail some possibility of getting economic and social benefits from it. The article shows that a person, who is liable to tax in a state, by staying in its territory, should not be excluded from the …

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Managing Fiscal Volatility By Redefining ‘Tax Cuts’ And ‘Tax Hikes’, David Gamage, Jeremy Bearer-Friend Dec 2009

Managing Fiscal Volatility By Redefining ‘Tax Cuts’ And ‘Tax Hikes’, David Gamage, Jeremy Bearer-Friend

David Gamage

This report analyzes how states should cope with fiscal volatility at the level of institutional-design policy. We propose that states reconsider how they define terms like ‘‘tax cuts’’ and ‘‘tax hikes.’’ By adopting a new baseline for defining those terms, states can increase the likelihood of using tax rate adjustments to cope with fiscal volatility rather than more harmful spending fluctuations.

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Comparative Income Taxation: A Structural Analysis, Hugh Ault, Brian Arnold Dec 2009

Comparative Income Taxation: A Structural Analysis, Hugh Ault, Brian Arnold

Hugh J. Ault

The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime …

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Preserving Tax Exempt Status For Your Nonprofit Client, Timothy R. Tarvin Dec 2009

Preserving Tax Exempt Status For Your Nonprofit Client, Timothy R. Tarvin

Timothy R Tarvin

In order to preserve a nonprofit’s tax-exempt status, counsel for the organization should stay current on how to appropriately file the IRS Form 990. Many American nonprofit organizations are at risk of losing their tax-exempt status due to changes in the tax code and filing deadlines. The Internal Revenue Service released a new version of the Form 990 in August of 2008, which became effective on December 31 the same year. This article tracks the changes on the form, as well as offers advice on who should file, when, and how. New tax law requires filing the Form 990 every …

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Taxation Of Workers In Sweden, Maria Hilling Dec 2009

Taxation Of Workers In Sweden, Maria Hilling

Maria Hilling

The Swedish national report for the EATLP Conference in Cambridge

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Integrating Iras With Snts, Thomas E. Simmons Dec 2009

Integrating Iras With Snts, Thomas E. Simmons

Thomas E. Simmons

What happens when a client's IRA (or qualified retirement plan) names a third party supplemental needs trust (SNT) as a beneficiary? From a tax perspective, the result might not be pretty. The difficulty in integrating an SNT with an IRA lies in the "see through trust" rules which must be observed in order to qualify for beneficial income tax treatment.

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