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Articles 1 - 13 of 13
Full-Text Articles in Law
Standing On The Shoulders Of Llcs: Tax Entity Status And Decentralized Autonomous Organizations, Samuel D. Brunson
Standing On The Shoulders Of Llcs: Tax Entity Status And Decentralized Autonomous Organizations, Samuel D. Brunson
Georgia Law Review
Since the formation of the first decentralized autonomous organization in 2016, their use has exploded. Thousands of DAOs now try to take advantage of smart contracts to solve a problem that plagues business entities: the gulf between ownership and management. Armed with smart contracts and requiring token-holders to vote on any change in strategy, DAOs dispense with the management layer so necessary in traditional business entities.
DAOs owe their existence to technology. Without blockchain, without cryptocurrency, and without smart contracts, there would be no DAOs. But they owe their explosive to something much more unexpected: Treasury regulations.
In the wake …
Stay Schemin’: Tax Court’S Recent Ruling On Credit Card Rewards And The Impact This Ruling Has On Future Rewards Programs, Hunter Davis
Stay Schemin’: Tax Court’S Recent Ruling On Credit Card Rewards And The Impact This Ruling Has On Future Rewards Programs, Hunter Davis
Georgia Law Review
Beyond the utility of actual “credit,” the most important perk cardholders seek to capitalize on are the rewards that each cardholder’s particular credit card offers. Cardholders look for the most bang for their buck in terms of rewards and points. Ranging from frequent flyer miles to cash back to everything in between, rewards programs have expanded and diversified rapidly over the past several decades, and consumers cannot get enough. So much so that the question of whether, and when, consumer loyalty rewards should be taxable has arisen and persists today. The Internal Revenue Service (IRS) and the Tax Court have …
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.)., Donald O. Clark
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.)., Donald O. Clark
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd
Georgia Journal of International & Comparative Law
No abstract provided.
The Impact Of The United States Tax Laws On International Technology Transfer: An Overview And Some Suggestion For Minimizing The Bite, Marcus B. Finnegan, Robert E. Mccarthy
The Impact Of The United States Tax Laws On International Technology Transfer: An Overview And Some Suggestion For Minimizing The Bite, Marcus B. Finnegan, Robert E. Mccarthy
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Tax Incentives To Exportation: Alternatives To Disc, Timothy A. Peterson
Georgia Journal of International & Comparative Law
No abstract provided.
Through The Antiboycott Morass To An Export Priority, Mark D. Menefee, Don Samuel
Through The Antiboycott Morass To An Export Priority, Mark D. Menefee, Don Samuel
Georgia Journal of International & Comparative Law
No abstract provided.
Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram
Income Tax - Foreign Earned Income Exclusion - Effect Of The Economic Recovery Tax Act Of 1981 On Citizens Or Residents Of The United States Living Abroad, Jonathan M. Engram
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii
Tax Planning: Foreign Investment In United States Real Property, William H. Newton Iii
Georgia Journal of International & Comparative Law
No abstract provided.
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Georgia Journal of International & Comparative Law
No abstract provided.
Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.
Foreign Oil And Taxation: The Need For A Coordinated Energy Policy, E.C. Lashbrooke Jr.
Georgia Journal of International & Comparative Law
No abstract provided.
Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne
Georgia Journal of International & Comparative Law
No abstract provided.
Structural Tax Exceptionalism, James M. Puckett
Structural Tax Exceptionalism, James M. Puckett
Georgia Law Review
Following the Supreme Court's landmark decision in Mayo Foundation for Medical Education and Research v. United States, many scholars of tax law have declared that Mayo marks the death of tax exceptionalism. The tax exceptionalist view holds that because tax is different or special, generally applicable administrative law procedural rules and doctrines do not apply in the tax context. In Mayo, however, the Supreme Court held that generally applicable administrative law rules and doctrines do apply to the Treasury Department and the IRS. Contrary to the prevailing narrative that proclaims the death of tax exceptionalism, this Article posits that the …