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Articles 1 - 5 of 5
Full-Text Articles in Law
Risky Ventures: The Impact Of Irs Health Care Joint Venture Policy, Roger P. Meyers
Risky Ventures: The Impact Of Irs Health Care Joint Venture Policy, Roger P. Meyers
University of Michigan Journal of Law Reform
IRS oversight of joint ventures between exempt and for-profit organizations has undergone substantial change over the past thirty years. This change has important consequences for the health care industry, where joint ventures have grown increasingly common. In the face of unclear guidance and aggressive enforcement of exemption-policing tools such as the private benefit doctrine and the control test, a hospital risks revocation of its tax-exempt status, or liability for unrelated business income tax, when it engages in a joint venture directly. It may be able to eliminate this risk by operating the same joint venture through a for-profit subsidiary; however, …
No Tax For "Phantom Income": How Congress Failed To Encourage Responsible Housing Consumption With Its Recent Tax Legislation, Rue Toland
Chicago-Kent Law Review
In the midst of the recent housing crisis, Congress passed two key pieces of federal tax legislation in an attempt to stem the tide of foreclosures and prevent further economic collapse. These two bills, the Mortgage Forgiveness Debt Relief Act in 2007 and the Housing and Economic Recovery Act in 2008, both sought competing goals: lessening the harm to existing homeowners, and encouraging purchases by new homebuyers. However, neither bill adequately addressed one of the root causes of the housing crisis, namely homeowners obtaining mortgages that, for whatever reason, they could not afford. Indeed, the tax incentives these bills created …
Flying Above The Law And Below The Radar: Instilling A Taxpaying Ethos In Those Playing By Their Own Rules, Richard Lavoie
Flying Above The Law And Below The Radar: Instilling A Taxpaying Ethos In Those Playing By Their Own Rules, Richard Lavoie
Pace Law Review
No abstract provided.
The Largest Loophole In Federal Tax Law: Preferential Capital Gain Treatment For Private Equity And Hedge Fund Managers' Carried Interests, 42 J. Marshall L. Rev. 529 (2009), Michael R. Pieczonka
The Largest Loophole In Federal Tax Law: Preferential Capital Gain Treatment For Private Equity And Hedge Fund Managers' Carried Interests, 42 J. Marshall L. Rev. 529 (2009), Michael R. Pieczonka
UIC Law Review
No abstract provided.
Use Of Judicial Doctrines In Federal Tax Cases Decided By Trial Courts, 1993-2006: A Quantitative Assessment, Daniel M. Schneider
Use Of Judicial Doctrines In Federal Tax Cases Decided By Trial Courts, 1993-2006: A Quantitative Assessment, Daniel M. Schneider
Cleveland State Law Review
The hypothesis of this Article is that the accepted wisdom--that judicial doctrines are raised exclusively by the government or the courts for the government's benefit--is wrong. Instead, judicial doctrines are used in a much richer manner by courts and by taxpayers, as well as the government, than the “wisdom” would suggest. It is the first paper to question the accepted thought about judicial doctrines and to do so using social science methodology. Starting at the end and working forward, the evidence assembled for this Article from a group of trial decisions about federal tax controversies establishes that, under the language …