Law Commons^™

Individual Income Taxation After The Tax Reform Act Of 1986, Louis A. Mezzullo

William & Mary Annual Tax Conference

No abstract provided.

The Alternative Minimum Tax For Individuals: Outline, Richard E. Fogg

William & Mary Annual Tax Conference

No abstract provided.

Accounting Methods After The Tax Reform Act Of 1986, Howard J. Busbee

William & Mary Annual Tax Conference

No abstract provided.

Capital Gains Exception To The House's "General Utilities" Repeal: Further Indigestions From Overly Processed "Corn Products", John W. Lee

Faculty Publications

In this article, Lee first describes the mechanics and tax effects of cost basis corporate acquisitions and analyzes why current tax rules favor such acquisitions over carryover basis acquisition (e .g., tax-free mergers); then he describes the House's proposed repeal in HR 3838 of the General Utilities doctrine in current sections 336-338, focusing on the continued exemption for long-term capital gains of a closely held active business corporation. This sets the stage for analysis of the Corn Products doctrine, which under an "integral asset" reading would deny the exemption to most appreciated operating assets, surely not the intent of the …

Efficiency And Income Taxes: The Rehabilitation Of Tax Incentives, Edward A. Zelinsky

Articles

This Article explores two prominent issues in current legal literature: the propriety of tax incentives in the federal income tax and the use of economic analysis to examine questions of concern to academic lawyers. One premise of this Article is that there is a connection between these two topics.

Taxation Of Natural Resources: Are Provisions Applying To The Domestic Natural Resources Industry Also Applicable To Deep Seabed Mining?, Jozef Leysen

LLM Theses and Essays

Deep seabed mining may diminish American dependence on foreign sources of minerals. It is thus in the interest of the United States (and other mineral importing countries) to encourage this highly risky industry and to provide for favorable legal conditions in general and for favorable tax conditions in particular. This thesis examines whether United States law on the taxation of natural resources applies to deep seabed mining.

Federal Tax Conformity - 1987: A Comparison Of Prior And New Federal And State Personal And Corporation Taxes, Senate Committee On Revenue And Taxation

California Senate

Covering Senate Bill 572 (Garamendi) and Assembly Bill 53 (Klehs)

Income Taxation Of Social Security Benefits: Balancing Social Policy With Tax Policy, Christopher R. Hoyt

Faculty Works

No abstract provided.

The Parenting Tax Penalty: A Framework For Income Tax Reform, Charles R.T. O'Kelley

Scholarly Works

Part I considers the proper tax treatment of out-of-pocket parenting expenses such as the costs incurred in providing food, clothing, shelter, and other goods and services to children for their consumption. Part I first characterizes the principal design alternatives to the present flat dependency deduction. It then examines the dominant accretion definition of income and concludes that the current flat dependency deduction is more consistent with the accretion concept and our actual governing beliefs than is any of the alternatives advocated by its critics.

Part II considers the tax relevance of imputed income from self-performed services. It explains (1) how …

Over The Back Fence: Tax Shelters And Other Sales Of Federal Income Tax Reductions, Thomas A. Robinson

Articles

No abstract provided.

The Federal Circuit's 1985 Tax Cases: The Exercise Of Equity, William S. Blatt

Articles

No abstract provided.

Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.

All Faculty Scholarship

As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies the tax treatment of the various types of payments that a partnership may make to a withdrawing partner. It introduced the concept of a liquidation of a partnership interest by the partnership itself, as opposed to the sale of that interest to an outsider or to the continuing partners. In some instances it provides tax consequences for continuing and withdrawing partners which are different from those attendant to a sale. It was designed to make the law concerning disposition of partnership interests simpler and …

Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven

Faculty Publications

No abstract provided.

The Character Of A Partner's Distributive Share Under The "Substantial Economic Effect" Regulation, Alan Gunn

Journal Articles

Partnership income and deductions are allocated according to the amount and the character of each partner's distributive share. This article examines the ways in which the section 704(b) regulations apply the "substantial economic effect" test to character allocations. It argues that it is important to distinguish allocations of character from allocations of amounts to understand these regulations. This is because tests that the regulations apply to character issues have to do with source-measurement correspondence and proration, while amounts are determined according to economic effect in the capital account sense. Although the regulations' rules for character allocations purport to define "substantiality," …

The Impact Of The Tax Reform Act Of 1986 On Legal Education And Law Faculty, Christopher R. Hoyt

Faculty Works

No abstract provided.