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Recent Developments In Federal Income Taxation: The Year 2013, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
Recent Developments In Federal Income Taxation: The Year 2013, Martin J. Mcmahon Jr., Ira B. Shepard, Daniel L. Simmons
UF Law Faculty Publications
This recent developments outline discusses, and provides context to understand the significance of, the most important judicial decisions and administrative rulings and regulations promulgated by the Internal Revenue Service and Treasury Department during the most recent twelve months. The outline focuses on primarily on topics of broad general interest — income tax accounting rules, determination of gross income, allowable deductions, treatment of capital gains and losses, corporate and partnership taxation, exempt organizations, and procedure and penalties. It deals summarily with qualified pension and profit sharing plans, and generally does not deal with international taxation or specialized industries, such as banking, …
Jurisdiction To Tax Corporations, Omri Y. Marian
Jurisdiction To Tax Corporations, Omri Y. Marian
UF Law Faculty Publications
Corporate tax residence is fundamental to our federal income tax system. Whether a corporation is classified as “domestic” or “foreign” for U.S. federal income tax purposes determines the extent of tax jurisdiction the United States has over the corporation and its affiliates. Unfortunately, tax scholars seem to agree that the concept of corporate tax residence is “meaningless.” Underlying this perception are the ideas that corporations cannot have “real” residence because they are imaginary entities and because taxpayers can easily manipulate corporate tax residence tests. Commentators try to deal with the perceived meaninglessness by either trying to identify a normative basis …