Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Section 162(a) (2)
- Tax (2)
- Affiliated group (1)
- Alt (1)
- American Opportunity Tax Credit (1)
-
- Charitable deduction (1)
- Contribution (1)
- Control (1)
- Disclosure (1)
- Donative intent (1)
- Education Expenses (1)
- Educational Assistance Programs (1)
- Election law (1)
- Executive compensation (1)
- Fellowship Grants (1)
- Full deduction rule (1)
- Golden parachute (1)
- Hope Scholarship Credit (1)
- Information (1)
- Legislation (1)
- Lifetime Learning Credit (1)
- Lobbying (1)
- Public law (1)
- Qualified Tuition Deduction (1)
- Reasonable compensation (1)
- Scholarships (1)
- Section 1504(a) (1)
- Section 162 (1)
- Section 162(a)(1) (1)
- Section 162(m) (1)
- Publication Year
- Publication
- Publication Type
Articles 1 - 30 of 59
Full-Text Articles in Law
Unauthorized Tax Elections, Jay A. Soled
Unauthorized Tax Elections, Jay A. Soled
Buffalo Law Review
Unauthorized tax elections are those devices and techniques that taxpayers employ to achieve sought-after objectives but that are not specifically endorsed under the Internal Revenue Code. Often evolving over time, they are a common feature of the nation’s tax system. While unauthorized tax elections can prove subversive, in many instances, if properly and timely addressed, their existence can produce salutary benefits vis-à-vis their eradication or formal institutionalization.
This analysis explores the general contours of unauthorized tax elections and the critical signaling roles that they provide, alerting Congress and the Treasury Department to shortcomings and vulnerabilities in the Internal Revenue Code’s …
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Buffalo Law Review
No abstract provided.
Failed Charity: Taking State Tax Benefits Into Account For Purposes Of The Charitable Deduction, Roger Colinvaux
Failed Charity: Taking State Tax Benefits Into Account For Purposes Of The Charitable Deduction, Roger Colinvaux
Buffalo Law Review
The Tax Cuts and Jobs Act (TCJA) substantially limited the ability of individuals to deduct state and local taxes (SALT) on their federal income tax returns. Some states are advancing schemes to allow taxpayers a state tax credit for contributions to a charity controlled by the state. The issue is whether state tax benefits are deductible as a charitable contribution for purposes of the federal income tax. Under a general rule of prior law—the full deduction rule—state tax benefits were ignored for purposes of the charitable deduction. If the full deduction rule is applied to the state workaround schemes, then …
Business Lobbying As An Informational Public Good: Can Tax Deductions For Lobbying Expenses Promote Transparency?, Michael Halberstam, Stuart G. Lazar
Business Lobbying As An Informational Public Good: Can Tax Deductions For Lobbying Expenses Promote Transparency?, Michael Halberstam, Stuart G. Lazar
Journal Articles
The view that “lobbying is essentially an informational activity” has persistently served the suggestion that lobbying provides a public good by educating legislators about policy and the consequences of legislation.
In this article, we link a proposed tax reform with a substantive disclosure requirement to promote the kind of “information subsidy” that serves the public interest, while mitigating – at least to some extent – the distortion that may result from the imbalance of financial resources on the business side and other institutional contraints identified in the literature. We argue that corporate lobbying should be encouraged – by allowing business …
The Unreasonable Case For A Reasonable Compensation Standard In The Public Company Context: Why It Is Unreasonable To Insist On Reasonableness, Stuart G. Lazar
The Unreasonable Case For A Reasonable Compensation Standard In The Public Company Context: Why It Is Unreasonable To Insist On Reasonableness, Stuart G. Lazar
Journal Articles
There is no question that corporate executives are well paid. But does high executive compensation mean excessive or unreasonable compensation? And if so, what is the solution to curbing the problem of excessive executive pay? More specifically, should the Internal Revenue Code be used as a means for regulating the actions of public companies?
This Article briefly explores these issues. In Part I, this Article provides a narrative of the excessive compensation debate. Without drawing a conclusion as to whether executive compensation is reasonably set or excessive in nature, Part I summarizes the history of public outrage surrounding executive pay. …
Schooling Congress: The Current Landscape Of The Tax Treatment Of Higher Education Expenses And A Framework For Reform, Stuart G. Lazar
Schooling Congress: The Current Landscape Of The Tax Treatment Of Higher Education Expenses And A Framework For Reform, Stuart G. Lazar
Journal Articles
Education may be a cornerstone of our society, but the tax treatment of higher education expenses does not appear to have resulted from an intellectual exercise that would make our nation’s educators’ proud. The Internal Revenue Code provides two separate, but equally unsatisfying, routes that allow taxpayers to offset their income with the costs of higher education. Where an individual can reduce her tax liability while receiving an education, the effect is to reduce significantly the cost of that education.
First, where amounts spent on education qualify as an “ordinary and necessary business expense,” a taxpayer will be entitled to …
Patenting The Tax Code: Monopolizing Basic Tax Strategy, Nicholas Robinson
Patenting The Tax Code: Monopolizing Basic Tax Strategy, Nicholas Robinson
Buffalo Intellectual Property Law Journal
No abstract provided.
To Tax Or Not To Tax, That Is The Question: The State Of Section 104(A)(2) Following Murphy V. Internal Revenue Service, Stuart G. Lazar
To Tax Or Not To Tax, That Is The Question: The State Of Section 104(A)(2) Following Murphy V. Internal Revenue Service, Stuart G. Lazar
Other Scholarship
No abstract provided.
The Definition Of Voting Stock And The Computation Of Voting Power Under Sections 368(C) And 1504(A): Recent Developments And Tax Lore, Stuart G. Lazar
The Definition Of Voting Stock And The Computation Of Voting Power Under Sections 368(C) And 1504(A): Recent Developments And Tax Lore, Stuart G. Lazar
Journal Articles
Although the concepts of "voting stock" and "voting power" are pervasive throughout the Code, until recently, courts, commentators and the Service have devoted minimal energy to demystifying the confusion surrounding the definition of voting stock and even less to expanding upon the methodology of computing voting power. Recent developments, however, may prompt practitioners to take a second look at these terms. While a 1995 decision by the Tax Court adds little to the existing body of authority with respect to the determination of the owner of voting stock, the Service's analysis of the voting power requirement in a 1994 private …
Irs Overhauls Spin-Off Ruling Guidelines, Stuart M. Finkelstein, Stuart G. Lazar
Irs Overhauls Spin-Off Ruling Guidelines, Stuart M. Finkelstein, Stuart G. Lazar
Other Scholarship
No abstract provided.
Debt Discharge Income: Kirby Lumber Co. Revisited Under The "Transactional Equity" Rule Of Hillsboro, Louis A. Del Cotto
Debt Discharge Income: Kirby Lumber Co. Revisited Under The "Transactional Equity" Rule Of Hillsboro, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
An Argument For Current Deductability Of A Target's Expenses In A "Friendly" Takeover, Charles A. Lofaso
An Argument For Current Deductability Of A Target's Expenses In A "Friendly" Takeover, Charles A. Lofaso
Buffalo Law Review
No abstract provided.
Spin-Offs Before And After The Tax Reform Act, Donald F. Brosnan
Spin-Offs Before And After The Tax Reform Act, Donald F. Brosnan
Buffalo Law Review
No abstract provided.
Class Tax To Mass Tax: The Role Of Propaganda In The Expansion Of The Income Tax During World War Ii, Carolyn C. Jones
Class Tax To Mass Tax: The Role Of Propaganda In The Expansion Of The Income Tax During World War Ii, Carolyn C. Jones
Buffalo Law Review
No abstract provided.
Double Benefits And Transactional Consistency Under The Tax Benefit Rule, Kenneth F. Joyce, Louis A. Del Cotto
Double Benefits And Transactional Consistency Under The Tax Benefit Rule, Kenneth F. Joyce, Louis A. Del Cotto
Journal Articles
No abstract provided.
Interest-Free Loans And Dickman V. Commissioner: A Letter To The Supreme Court, Louis A. Del Cotto, Kenneth F. Joyce
Interest-Free Loans And Dickman V. Commissioner: A Letter To The Supreme Court, Louis A. Del Cotto, Kenneth F. Joyce
Buffalo Law Review
No abstract provided.
Re-Examining The Sham Doctrine: When Should An Overpayment Be Reflected In Basis?, Mitchell M. Gans
Re-Examining The Sham Doctrine: When Should An Overpayment Be Reflected In Basis?, Mitchell M. Gans
Buffalo Law Review
No abstract provided.
Interest-Free Loans: The Odyssey Of A Misnomer, Kenneth F. Joyce, Louis A. Del Cotto
Interest-Free Loans: The Odyssey Of A Misnomer, Kenneth F. Joyce, Louis A. Del Cotto
Journal Articles
No abstract provided.
The Double Jeopardy Of Corporate Profits, Constantine N. Katsoris
The Double Jeopardy Of Corporate Profits, Constantine N. Katsoris
Buffalo Law Review
No abstract provided.
Inherited Excess Mortgage Property: Death And The Inherited Tax Shelter, Louis A. Del Cotto, Kenneth F. Joyce
Inherited Excess Mortgage Property: Death And The Inherited Tax Shelter, Louis A. Del Cotto, Kenneth F. Joyce
Journal Articles
No abstract provided.
Tax Superiority In Bankruptcy—A Study Of Business Bankruptcy Distributions In The Southern And Western Districts Of New York, Peter D. Wolfson
Tax Superiority In Bankruptcy—A Study Of Business Bankruptcy Distributions In The Southern And Western Districts Of New York, Peter D. Wolfson
Buffalo Law Review
No abstract provided.
Sales And Other Dispositions Of Property Under Section 1001: The Taxable Event, Amount Realized And Related Problems Of Basis, Louis A. Del Cotto
Sales And Other Dispositions Of Property Under Section 1001: The Taxable Event, Amount Realized And Related Problems Of Basis, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
The Continued Vaildity Of The Supreme Court's Broad Approach To Income In James V. United States, William B. Barker
The Continued Vaildity Of The Supreme Court's Broad Approach To Income In James V. United States, William B. Barker
Buffalo Law Review
No abstract provided.
The Ab (Abc) And Ba Transactions: An Economic And Tax Analysis Of Reserved And Carved Out Income Interests, Kenneth F. Joyce, Louis A. Del Cotto
The Ab (Abc) And Ba Transactions: An Economic And Tax Analysis Of Reserved And Carved Out Income Interests, Kenneth F. Joyce, Louis A. Del Cotto
Journal Articles
No abstract provided.
Section 357(C): Some Observations On Tax Effects To The Cash Basis Transferor, Louis A. Del Cotto
Section 357(C): Some Observations On Tax Effects To The Cash Basis Transferor, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
Sexism In The Code: A Comparative Study Of Income Taxation Of Working Wives And Mothers, Grace Blumberg
Sexism In The Code: A Comparative Study Of Income Taxation Of Working Wives And Mothers, Grace Blumberg
Buffalo Law Review
No abstract provided.
Taxation—Tax Benefit Rule Applicable To Section 357 Liquidations, Thomas A. Palmer
Taxation—Tax Benefit Rule Applicable To Section 357 Liquidations, Thomas A. Palmer
Buffalo Law Review
Commissioner v. Anders, 414 F.2d 1283 (10th Cir. 1969).
Taxation—Stipends Given In Conjunction With Employer Doctoral Programs Are Taxable As Compensation For Employment, A. Bruce Norton
Taxation—Stipends Given In Conjunction With Employer Doctoral Programs Are Taxable As Compensation For Employment, A. Bruce Norton
Buffalo Law Review
Bingler v. Johnson, 394 U.S. 741 (1969).
Taxation—Tax Avoidance Need Only Be One Of The Purposes For Imposition Of The Accumulated Earnings Tax, Jerome M. Hesch
Taxation—Tax Avoidance Need Only Be One Of The Purposes For Imposition Of The Accumulated Earnings Tax, Jerome M. Hesch
Buffalo Law Review
United States v. The Donruss Company, 393 U.S. 297 (1969).
Taxation—Kimbell-Diamond Still Available As An Adjunct To Section 334(B)(2)., Harry Sushek
Taxation—Kimbell-Diamond Still Available As An Adjunct To Section 334(B)(2)., Harry Sushek
Buffalo Law Review
American Potash and Chemical Corp. v. United States, 399 F.2d 194 (Ct. Cl. 1968).