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Full-Text Articles in Law
Ground Zero: The Irs Attack On Syndicated Conservation Easements, Beckett G. Cantley, Geoffrey C. Dietrich
Ground Zero: The Irs Attack On Syndicated Conservation Easements, Beckett G. Cantley, Geoffrey C. Dietrich
William & Mary Environmental Law and Policy Review
On June 25, 2020, the Internal Revenue Service (“IRS”) announced a settlement initiative (“SI”) to certain taxpayers with pending docketed cases involving syndicated conservation easement (“SCE”) transactions. The SI is the current culmination of a long series of attacks by the IRS against SCE transactions. The IRS has recently found success in the Tax Court against SCEs, but the agency’s overall legal position may be overstated. It is possible that the recent SI is merely an attempt to capitalize on leverage while the IRS has it. Regardless, the current state of the law surrounding SCEs is murky at best. Whether …
Reforming The Charitable Contribution Tax Deduction: Accounting For Random Acts Of Charity, Janene R. Finley
Reforming The Charitable Contribution Tax Deduction: Accounting For Random Acts Of Charity, Janene R. Finley
William & Mary Business Law Review
Concern for the tax treatment of charitable contributions has increased as a result of the Tax Cuts and Jobs Act of 2017. Although the new law increased the limitation of deductible charitable contributions to 60 percent of adjusted gross income, the standard deduction was also increased. Increasing the standard deduction is expected to reduce the number of taxpayers who are able to itemize their deductions in the next tax year, which is expected to reduce charitable giving in the future. This Article discusses proposals to amend the Internal Revenue Code to promote charitable giving, including a non-itemizer deduction. In addition, …
The Effects Of The Virginia Land Preservation Credit On Federal Taxable Income: Should The Right Hand Take From What The Left Hand Gave?, W. Eugene Seago
The Effects Of The Virginia Land Preservation Credit On Federal Taxable Income: Should The Right Hand Take From What The Left Hand Gave?, W. Eugene Seago
William & Mary Environmental Law and Policy Review
No abstract provided.
Doping Out The Capitalization Rules After Indopco, John W. Lee
Doping Out The Capitalization Rules After Indopco, John W. Lee
Faculty Publications
In this article, Lee provides guidance for Treasury and the IRS (in their promised clarification of application of INDOPCO). He delineates how to avoid what he perceives as the past pitfalls of capitalization of recurring, insubstantial, or relatively short-lived expenditures with Ito, or inadequate, amortization. The article also sets forth models for (a) amortizing as. a freestanding deferred charge long-lived substantial self-created intangibles such as business expansion costs, including employee training costs, and (b) expensing, or perhaps better, amortizing currently less substantial or regularly recurring, steady state self-created intangibles (such as repairs and advertising, respectively).
Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven
Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven
Faculty Publications
No abstract provided.
The Alternative Minimum Tax: Proving Again That Two Wrongs Do Not Make A Right, Glenn E. Coven
The Alternative Minimum Tax: Proving Again That Two Wrongs Do Not Make A Right, Glenn E. Coven
Faculty Publications
No abstract provided.
Federal Income Taxation: Meals And Lodging Furnished For The Convenience Of The Employer - Two Sequels To The Boykin Case, Rexford R. Cherryman
Federal Income Taxation: Meals And Lodging Furnished For The Convenience Of The Employer - Two Sequels To The Boykin Case, Rexford R. Cherryman
William & Mary Law Review
No abstract provided.
Federal Income Taxation: Deductability Of Medical Expenses Which Are Also Personal Expenses, Ronald L. Buckwalter
Federal Income Taxation: Deductability Of Medical Expenses Which Are Also Personal Expenses, Ronald L. Buckwalter
William & Mary Law Review
No abstract provided.