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Articles 1 - 15 of 15
Full-Text Articles in Law
Tax Reform On Homeownership, Margaret Ryznar
Tax Reform On Homeownership, Margaret Ryznar
University of Miami Law Review
The 2017 tax reform, by curtailing the deductions for mortgage interest and state and local taxes, frustrates the American public policy of encouraging homeownership. Yet, there are many reasons that public policy has encouraged homeownership for decades. Most importantly, homeownership is an important savings tool for Americans—and tax reform should be mindful of it.
The Mapmaker’S Dilemma In Evaluating High-End Inequality, Daniel Shaviro
The Mapmaker’S Dilemma In Evaluating High-End Inequality, Daniel Shaviro
University of Miami Law Review
The last thirty years have witnessed rising income and wealth concentration among the top 0.1% of the population, leading to intense political debate regarding how, if at all, policymakers should respond. Often, this debate emphasizes the tools of public economics, and in particular optimal income taxation. However, while these tools can help us in evaluating the issues raised by high-end inequality, their extreme reductionism—which, in other settings, often offers significant analytic payoffs—here proves to have serious drawbacks. This Article addresses what we do and don’t learn from the optimal income tax literature regarding high-end inequality, and what other inputs might …
Dodging The Taxman: Why The Treasury’S Anti-Abuse Regulation Is Unconstitutional, Linda D. Jellum
Dodging The Taxman: Why The Treasury’S Anti-Abuse Regulation Is Unconstitutional, Linda D. Jellum
University of Miami Law Review
To combat abusive tax shelters, the Department of the Treasury promulgated a general anti-abuse regulation applicable to all of subchapter K of the Internal Revenue Code of 1986. The Treasury targeted subchapter K because unique aspects of the partnership tax laws—including its aggregate-entity dichotomy—foster creative tax manipulation. In the anti-abuse regulation, the Treasury attempted to “codify” existing judicially-created anti-abuse doctrines, such as the business-purpose and economic-substance doctrines. Also, and more surprisingly, the Treasury directed those applying subchapter K to use a purposivist approach to interpretation and to reject textualism.
In this article, I demonstrate that the Treasury exceeded both its …
The Deemed Transfer Of Recourse Liabilities Leads To Owen Taxes: What Is Wrong With Form Over Substance?, Christine L. Agnew
The Deemed Transfer Of Recourse Liabilities Leads To Owen Taxes: What Is Wrong With Form Over Substance?, Christine L. Agnew
University of Miami Law Review
No abstract provided.
Selected International Aspects Of Fundamental Tax Reform Proposals, Stephen E. Shay, Victoria P. Summers
Selected International Aspects Of Fundamental Tax Reform Proposals, Stephen E. Shay, Victoria P. Summers
University of Miami Law Review
No abstract provided.
The Future Of Capital Export Neutrality: A Comment On Robert Peroni's Path To Progressive Reform Of The U.S. International Tax Rules, Stanley I. Langbein
The Future Of Capital Export Neutrality: A Comment On Robert Peroni's Path To Progressive Reform Of The U.S. International Tax Rules, Stanley I. Langbein
University of Miami Law Review
No abstract provided.
Comment On Shay And Summers: Selected International Aspects Of Fundamental Tax Reform Proposals, Reuven S. Avi-Yonah
Comment On Shay And Summers: Selected International Aspects Of Fundamental Tax Reform Proposals, Reuven S. Avi-Yonah
University of Miami Law Review
No abstract provided.
Back To The Future: A Path To Progressive Reform Of The U.S. International Income Tax Rules, Robert J. Peroni
Back To The Future: A Path To Progressive Reform Of The U.S. International Income Tax Rules, Robert J. Peroni
University of Miami Law Review
No abstract provided.
Comments On Professor Peroni's Paper On Reform Of The U.S. International Income Tax Rules, David R. Tillinghast
Comments On Professor Peroni's Paper On Reform Of The U.S. International Income Tax Rules, David R. Tillinghast
University of Miami Law Review
No abstract provided.
Comment: What's On Second?, George Mundstock
Comment: What's On Second?, George Mundstock
University of Miami Law Review
No abstract provided.
International Aspects Of Fundamental Tax Restructuring: Practice Or Principle?, Michael J. Graetz
International Aspects Of Fundamental Tax Restructuring: Practice Or Principle?, Michael J. Graetz
University of Miami Law Review
No abstract provided.
Internal Revenue Code Section 197: A Cure For The Controversy Over The Amortization Of Acquired Intangible Assets, Gregory M. Beil
Internal Revenue Code Section 197: A Cure For The Controversy Over The Amortization Of Acquired Intangible Assets, Gregory M. Beil
University of Miami Law Review
No abstract provided.
The Tax Benefit Rule: Recovery Reevaluated, Paul T. Kestenbaum
The Tax Benefit Rule: Recovery Reevaluated, Paul T. Kestenbaum
University of Miami Law Review
The United States Supreme Court has granted certiorari in two cases, Bliss Dairy, Inc. v. United States and Hillsboro National Bank v. Commissioner, to resolve a conflict in the circuits as to whether recovery is necessary for the application of the tax benefit rule. The author argues that the application of the tax benefit rule should not depend on the existence of a recovery, but instead should depend on whether an event occurs that is inconsistent with the assumptions underlying the prior deduction; recovery merely is a manifestation of an inconsistent event.
The Likely Source: An Unexplored Weakness In The Net Worth Method Of Proof, Ian M. Comisky
The Likely Source: An Unexplored Weakness In The Net Worth Method Of Proof, Ian M. Comisky
University of Miami Law Review
The government will often suspect a taxpayer of tax evasion if it discovers that the taxpayer's net worth has increased and that the taxpayer did not report the full amount of the increase as taxable income. If the government can establish a likely source for the increase, a jury will be permitted to infer that the taxpayer derived the increase from currently taxable and unreported income. In this article, the author discusses the origins, development, and varied applications of this "likely source inference." Then, after critically examining the constitutional underpinnings of the inference, the author argues that the inference is …
U.S. Taxation Of U.S. Real Estate Owned By Nonresident Aliens And Foreign Corporations, Robert B. Alexander Jr.
U.S. Taxation Of U.S. Real Estate Owned By Nonresident Aliens And Foreign Corporations, Robert B. Alexander Jr.
University of Miami Law Review
No abstract provided.