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Articles 1 - 13 of 13
Full-Text Articles in Law
Tax Glasnost' For Millionaires: Peeking Behind The Veil Of Ignorance Along The Publicity-Privacy Continuum, Marc Linder
Tax Glasnost' For Millionaires: Peeking Behind The Veil Of Ignorance Along The Publicity-Privacy Continuum, Marc Linder
Marc Linder
No abstract provided.
Eisenhower-Era Marxist-Confiscatory Taxation: Requiem For The Rhetoric Of Rate Reduction For The Rich, Marc Linder
Eisenhower-Era Marxist-Confiscatory Taxation: Requiem For The Rhetoric Of Rate Reduction For The Rich, Marc Linder
Marc Linder
No abstract provided.
The Involuntary Conversion Of Employees Into Self-Employed: The Internal Revenue Service And Section 530, Marc Linder
The Involuntary Conversion Of Employees Into Self-Employed: The Internal Revenue Service And Section 530, Marc Linder
Marc Linder
No abstract provided.
No Wealthy Parent Left Behind: An Analysis Of Tax Subsidies For Higher Education, Andrew Pike
No Wealthy Parent Left Behind: An Analysis Of Tax Subsidies For Higher Education, Andrew Pike
Andrew Pike
This article analyzes the status in 2007 of higher education costs in relation to U.S. taxation policy and the declining real income and ability of lower and middle income taxpayers to pay tuition and fees. Then-current tax policy lessened support for families with the greatest financial need while providing much greater levels of support to those with greater financial resources. To enhance distributional fairness, the author proposes that Congress repeal tax provisions that have this effect and consolidate the separate sources of federal financial aid grants into one program--an expanded Pell Grant program. He also advises that Congress make the …
Transferee Liability, George Hani, Tamara Ashford, Robert D. Probasco
Transferee Liability, George Hani, Tamara Ashford, Robert D. Probasco
Robert Probasco
No abstract provided.
Quoted In Daily Tax Report On Starnes Ruling, Robert D. Probasco
Quoted In Daily Tax Report On Starnes Ruling, Robert D. Probasco
Robert Probasco
No abstract provided.
Foreign Administrative Law And International Taxation: A Case Study Of Tax Treaty Implementation In China, Wei Cui
Wei Cui
U.S. taxpayers and the IRS increasingly have to take into account the interactions between U.S. and foreign laws, but they have paid little attention to the administrative law backgrounds of foreign tax laws. In a growing range of cases, the need for such attention has become urgent. This Article describes a novel class of cases encountered by U.S. taxpayers that emanate from tax treaty implementation in China. In these cases, U.S. (and other foreign) investors face certain rules that conflict with common treaty interpretations, and that, at the same time, are not legally binding under Chinese domestic law. The question …
The Marriage Tax Revisited: An Analysis Of The Tax Consequences Of Marriage, Dan Subotnik
The Marriage Tax Revisited: An Analysis Of The Tax Consequences Of Marriage, Dan Subotnik
Dan Subotnik
No abstract provided.
Quoted In Law360 On Ex-Ceo Pay, Robert D. Probasco
Quoted In Law360 On Ex-Ceo Pay, Robert D. Probasco
Robert Probasco
No abstract provided.
Comments On Proposed Amendments To The Rules Of The United States Tax Court, Robert D. Probasco
Comments On Proposed Amendments To The Rules Of The United States Tax Court, Robert D. Probasco
Robert Probasco
Section 7433’S Statute Of Limitations: How Courts Have Wrongly Turned A Taxpayer’S Exclusive Sword Into The Irs’ Shield Against Damages, Diana Leyden
Diana L Leyden
Despite the importance of section 7433 to check government unauthorized tortious collection activity, federal courts have turned section 7433 into a shield against excessive or unsupported IRS action, rather than maintain it as the small, but important, sword that Congress intended to give taxpayer. This article contributes to the sparse literature on section 7433 by demonstrating that federal courts have effectively vitiated section 7433 by misreading its statute of limitations to: (1) require a taxpayer to be put on notice that all collection action taken by the IRS is unauthorized and to therefore file section 7433 actions from the first …
Compromising The Safety Net: How Limiting Tax Deductions For High-Income Donors Could Undermine Charitable Organizations, Patrick Tolan
Compromising The Safety Net: How Limiting Tax Deductions For High-Income Donors Could Undermine Charitable Organizations, Patrick Tolan
Patrick E. Tolan Jr.
President Obama’s recent budget proposals have contemplated reducing the top rate for charitable deductions (and all itemized deductions) to twenty-eight percent. Because America’s largest donors are those in the highest marginal tax brackets, efforts to limit deductibility of charitable donations could have a chilling effect on charitable giving.
In this article the author looks at motivations for charitable donations and specifically at the impact of tax deductibility as a motivating factor. It takes a historical look at the philanthropic surveys and econometric models and examines empirical data concerning impacts of significant changes to the tax code in the 1980s that …
Nonprofits, Politics, And Privacy, Lloyd Hitoshi Mayer
Nonprofits, Politics, And Privacy, Lloyd Hitoshi Mayer
Lloyd Hitoshi Mayer
The time is ripe for a deeper consideration of the policy concerns that underlie public disclosure requirements for politically active tax-exempt nonprofit organizations and the related issue of privacy. To clarify the discussion, one aspect for deeper consideration is recognizing that this particular area is at the intersection of three significantly different disclosure regimes. Those three regimes are (1) federal tax law generally, (2) federal tax law as it applies to tax-exempt nonprofit organizations, and (3) federal election law. These regimes are a study in contrasts. Federal tax law strongly protects taxpayer information from public disclosure. And while federal tax …