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Articles 1 - 30 of 68
Full-Text Articles in Law
Contractual Tax Reform, Michael Abramowicz, Andrew Blair-Stanek
Contractual Tax Reform, Michael Abramowicz, Andrew Blair-Stanek
William & Mary Law Review
One-size-fits-all taxation fails to accommodate diverse taxpayer circumstances. This Article proposes allowing taxpayers to contract into alternative tax regimes administered by private intermediaries. Participating taxpayers would make payments to the intermediaries pursuant to contract, and the intermediaries would be required to pay to the government at least as much as these taxpayers would have paid the government otherwise. That amount is determined based on the actual tax receipts of a control group, taxpayers who wish to contract with an intermediary but instead are chosen at random to continue under the status quo. These alternative tax regimes might better accommodate taxpayers’ …
Tax Lawyers As Tax Insurance, Heather M. Field
Tax Lawyers As Tax Insurance, Heather M. Field
William & Mary Law Review
Transactional tax lawyers, by rendering tax opinions, provide a version of insurance to clients. This insurance is clearly incomplete, but by providing a tax opinion, a lawyer conditionally agrees to indemnify the client for at least part of the potential loss the client incurs if the favorable tax treatment described in the opinion is successfully challenged. Although insurance is not the primary function of transactional tax lawyers, and although this Article does not argue that tax opinions should be regulated as insurance, indemnification—a key element of insurance—is an important part of the economic relationship between a client and a lawyer …
Netflix And Quill: Using Access And Consumption To Create A Plan For Taxing The Cloud, William L. Fletcher Jr.
Netflix And Quill: Using Access And Consumption To Create A Plan For Taxing The Cloud, William L. Fletcher Jr.
William & Mary Law Review
No abstract provided.
Parting The Dark Money Sea: Exposing Politically Active Tax-Exempt Groups Through Fec-Irs Hybrid Enforcement, Carrie E. Miller
Parting The Dark Money Sea: Exposing Politically Active Tax-Exempt Groups Through Fec-Irs Hybrid Enforcement, Carrie E. Miller
William & Mary Law Review
No abstract provided.
Suitable For Framing: Business Deductions In A Net Income Tax System, David I. Walker
Suitable For Framing: Business Deductions In A Net Income Tax System, David I. Walker
William & Mary Law Review
The federal tax code includes numerous provisions disallowing or curtailing income tax deductions related to such disparate activities as business lobbying and providing non-performance-based compensation to senior corporate executives. The primary claim of this article is that a tendency to mentally frame business deductions as subsidies, often reinforced by rhetoric explicitly framing deductions as subsidies, helps explain these provisions. The traditional “public policy” disallowances directed at lobbying, fines and penalties paid by businesses, and antitrust treble damages respond to an appearance of a taxpayer subsidy that would follow from deduction, despite the fact that it is far from clear that …
Why Are There Tax Havens?, Adam H. Rosenzweig
Why Are There Tax Havens?, Adam H. Rosenzweig
William & Mary Law Review
Recently, the issue of tax havens has risen to the fore of the fiscal policy debate, with tax havens being singled out as the root cause of many of the fiscal shortfalls plaguing the governments of the world. Surprisingly, however, although there has been a fair amount of literature on why tax havens are harmful to the modern international tax regime, which countries become tax havens, and what means are available to combat tax havens, there has been less written specifically on the underlying question of why, notwithstanding all these points, tax havens exist in the first place, or why …
The Tax Consequences Of The Statutory Right Of Redemption In Property Foreclosures, C. Barrett Pasquini
The Tax Consequences Of The Statutory Right Of Redemption In Property Foreclosures, C. Barrett Pasquini
William & Mary Law Review
No abstract provided.
A Devil Disguised As A Corporate Angel?: Questioning Corporate Charitable Contributions To "Independent" Directors' Organizations, Benjamin E. Ladd
A Devil Disguised As A Corporate Angel?: Questioning Corporate Charitable Contributions To "Independent" Directors' Organizations, Benjamin E. Ladd
William & Mary Law Review
No abstract provided.
Commercial Activity And Charitable Tax Exemption, John D. Colombo
Commercial Activity And Charitable Tax Exemption, John D. Colombo
William & Mary Law Review
No abstract provided.
Corporate Managers, Agency Costs, And The Rise Of Double Taxation, Steven A. Bank
Corporate Managers, Agency Costs, And The Rise Of Double Taxation, Steven A. Bank
William & Mary Law Review
No abstract provided.
A Wrong Step In The Right Direction: The National Taxpayer Advocate And The 1998 Irs Restructuring And Reform Act, Heather B. Conoboy
A Wrong Step In The Right Direction: The National Taxpayer Advocate And The 1998 Irs Restructuring And Reform Act, Heather B. Conoboy
William & Mary Law Review
No abstract provided.
Internal Revenue Code Section 1259: A Legitimate Foundation For Taxing Short Sales Against The Box Or A Mere Makeover?, Simon D. Ulcickas
Internal Revenue Code Section 1259: A Legitimate Foundation For Taxing Short Sales Against The Box Or A Mere Makeover?, Simon D. Ulcickas
William & Mary Law Review
No abstract provided.
Three Versions Of Tax Reform, Alvin C. Warren Jr.
Three Versions Of Tax Reform, Alvin C. Warren Jr.
William & Mary Law Review
No abstract provided.
Everything Old Is New Again: Reaching The Limits Of Indopco's Future Benefits With The Just-In-Time Management Philosophy, Glenn Walberg
Everything Old Is New Again: Reaching The Limits Of Indopco's Future Benefits With The Just-In-Time Management Philosophy, Glenn Walberg
William & Mary Law Review
No abstract provided.
The Infield Fly Rule And The Internal Revenue Code: An Even Further Aside, Mark W. Cochran
The Infield Fly Rule And The Internal Revenue Code: An Even Further Aside, Mark W. Cochran
William & Mary Law Review
No abstract provided.
Container Corporation Of America V. Franchise Tax Board: The Supreme Court Encourages Apportionment Taxation, Laura J. Waterland
Container Corporation Of America V. Franchise Tax Board: The Supreme Court Encourages Apportionment Taxation, Laura J. Waterland
William & Mary Law Review
No abstract provided.
Jackson Reanalyzed: Preventing Tax-Free Escape Upon Transfer Of A Partnership Interest, Michael J. Baader
Jackson Reanalyzed: Preventing Tax-Free Escape Upon Transfer Of A Partnership Interest, Michael J. Baader
William & Mary Law Review
No abstract provided.
The Taxation Of Reinvested Corporate Earnings, Richard L. Doernberg
The Taxation Of Reinvested Corporate Earnings, Richard L. Doernberg
William & Mary Law Review
No abstract provided.
A Decision Model For Lease Parties In Sale-Leasebacks Of Real Estate, Nancy E. Shurtz
A Decision Model For Lease Parties In Sale-Leasebacks Of Real Estate, Nancy E. Shurtz
William & Mary Law Review
No abstract provided.
Tax Status Of Private Segregated Schools: The New Revenue Procedure, Wilfred F. Drake
Tax Status Of Private Segregated Schools: The New Revenue Procedure, Wilfred F. Drake
William & Mary Law Review
No abstract provided.
Standing To Challenge Tax Treatment Of Competitors
Standing To Challenge Tax Treatment Of Competitors
William & Mary Law Review
No abstract provided.
Challenging The Tax Summons: Procedures And Defenses
Challenging The Tax Summons: Procedures And Defenses
William & Mary Law Review
No abstract provided.
Carrybacks And The (F) Reorganization
Muni-Funds: Exempt-Interest Dividends And The Feasibility Of Underwriting Fee Recapture
Muni-Funds: Exempt-Interest Dividends And The Feasibility Of Underwriting Fee Recapture
William & Mary Law Review
No abstract provided.
Crown V. Commissioner: Gift Taxation And Interest-Free Loans Among Family Members
Crown V. Commissioner: Gift Taxation And Interest-Free Loans Among Family Members
William & Mary Law Review
No abstract provided.
Taxation Of Professional Sports Teams After 1976: A Whole New Ballgame, Howard Zaritsky
Taxation Of Professional Sports Teams After 1976: A Whole New Ballgame, Howard Zaritsky
William & Mary Law Review
No abstract provided.
Bartlett V. United States: Deduction Of Nonbusiness Losses Not Compensated By Insurance - The Need For A Separate Standard For Individuals
William & Mary Law Review
No abstract provided.
Analysis Of Revenue Ruling 75-292: A Proposal To Allow The Combined Use Of Sections 1031 And 351 Without Destroying The Tax-Free Status Of Either
William & Mary Law Review
No abstract provided.
Tax Planning For Compensation Of Service Partners
Tax Planning For Compensation Of Service Partners
William & Mary Law Review
No abstract provided.
The Taxpayer's Expectation Of Privacy As A Bar To Production Of Records Held By His Attorney
The Taxpayer's Expectation Of Privacy As A Bar To Production Of Records Held By His Attorney
William & Mary Law Review
No abstract provided.