Law Commons^™

Controversies In Tax Law: A Matter Of Perspective (Introduction), Anthony C. Infanti

Book Chapters

This volume presents a new approach to today’s tax controversies, reflecting that debates about taxation often turn on the differing worldviews of the debate participants. For instance, a central tension in the academic tax literature — which is filtering into everyday discussions of tax law — exists between “mainstream” and “critical” tax theorists. This tension results from a clash of perspectives: Is taxation primarily a matter of social science or social justice? Should tax policy debates be grounded in economics or in critical race, feminist, queer, and other outsider perspectives?

To capture and interrogate what often seems like a chasm …

Reinvigorating The Reit's Neutrality And Capital Formation Purposes Through A Modernized Tax Integration Model, Simon Johnson

The Journal of Business, Entrepreneurship & the Law

Efforts at reform have not spared the REIT arrangement, but have focused on objectives unrelated to its model of tax integration, despite its significant flaws. Owing to the interaction of several provisions, the model largely precludes capitalization through retained earnings. This increases the cost of REIT capital and limits its capacity to realize the neutrality and private real estate capital formation objectives Congress pursued in creating the arrangement. Accordingly, it is important to consider how to durably improve the REIT tax integration model. Ultimately, the article concludes that the shareholder allocation model, a complete integration model conceptually similar to the …

The Myth Of The Matching Principle As A Tax Value, Deborah A. Geier

Law Faculty Articles and Essays

This 1998 article explores why the "matching principle" in financial accounting should be considered irrelevant to federal income taxation, where its application can result effectively in consumption taxation (as opposed to income taxation).

Tax Consequences Of Purchases Of Computer Hardware And Software, Robert W. Malone

Akron Tax Journal

The advent of the computer age has resulted in a significant increase in the investment by businesses in computer hardware and software. The term "hardware" refers to the physical equipment which accepts (input), processes, and prints (output) information received by it. The term "software" refers to the instructions (language) used to direct a computer to perform desired tasks and the documentation (discs, tapes, etc.) on which such instructions are recorded.' Examples of types of software include Basic, Fortran, Cobol, and RPG. This article addresses the tax aspects and planning opportunities associated with the purchases of computer hardware and software.