Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 4 of 4
Full-Text Articles in Law
Meaningless Comparisons: Corporate Tax Reform Discourse In The United States, Omri Y. Marian
Meaningless Comparisons: Corporate Tax Reform Discourse In The United States, Omri Y. Marian
UF Law Faculty Publications
This article examines the role that international comparisons play in current corporate tax reform discourse in the United States. Citing the need to make the U.S. corporate tax system more competitive, comparisons are frequently used to assess other jurisdictions' tax-competitiveness, and many legislative proposals are supported by such comparative arguments. Examining such discourse against the background of several theoretical approaches to comparative law, this article argues that, to the extent that comparisons are aimed at providing guidance for prospective reform, this purpose is not well served. Participants in the corporate tax reform discourse, from both sides of the aisle, lack …
Managing The Next Deluge: A Tax System Approach To Flood Insurance, Charlene Luke, Aviva Abramovsky
Managing The Next Deluge: A Tax System Approach To Flood Insurance, Charlene Luke, Aviva Abramovsky
UF Law Faculty Publications
The National Flood Insurance Program (NFIP) has fallen short in fulfilling its promise as a social safety net for flood loss victims. In place of the NFIP, this Article proposes a mandatory social insurance plan that would harness the strengths of the federal taxing authority to provide basic relief for flood losses occurring at an individual’s primary residence. Any plan for addressing flood loss must navigate hotly debated, competing views about government intervention, redistribution, private markets, environmental protection, and property rights. This Article argues that government intervention in flood loss relief is inevitable, at least in the foreseeable future, and …
Understanding Consolidated Returns, Martin J. Mcmahon Jr.
Understanding Consolidated Returns, Martin J. Mcmahon Jr.
UF Law Faculty Publications
Section 1501 allows all of the members of an affiliated group of corporations to elect to file a consolidated return. A consolidated return permits the includible members of an affiliated group of corporations to combine their incomes into a single return. The detailed rules for filing consolidated returns are found in regulations promulgated pursuant to a broad delegation of authority in section 1502 of the Internal Revenue Code. In general, the regulations reflect a “single entity” approach that attempts to treat the several members of a consolidated group in the same manner as divisions of a single corporation. This article …
Recent Developments In Federal Income Taxation: The Year 2011, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Recent Developments In Federal Income Taxation: The Year 2011, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
UF Law Faculty Publications
This recent developments outline discusses, and provides context to understand the significance of, the most important judicial decisions and administrative rulings and regulations promulgated by the Internal Revenue Service and Treasury Department during the most recent twelve months - and sometimes a little farther back in time if we find the item particularly humorous or outrageous. Most Treasury Regulations, however, are so complex that they cannot be discussed in detail and, anyway, only a devout masochist would read them all the way through; just the basic topic and fundamental principles are highlighted - unless one of us decides to go …