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Articles 1 - 30 of 106
Full-Text Articles in Law
Will States Step Up In 2020? We Hope So, Darien Shanske, David Gamage
Will States Step Up In 2020? We Hope So, Darien Shanske, David Gamage
Articles by Maurer Faculty
We offer no predictions about the next year in tax, but we will offer what we hope will happen — if not next year, then soon. To paraphrase Chief Justice John Roberts, we hope that when it comes to the taxation of multinational corporations in particular, states will act more like the “separate and independent sovereigns” that they are. often rely on volatile revenue sources. More stable tax bases, like the sales tax and the property tax bases, are riddled with design flaws, from the sales tax base not including services and intangibles to the property tax failing to provide …
A Current Update Of Epcrs Through Rev. Proc. 2019-19, 47 Tax Mgmt. Comp. Plan. J. 1 (Dec. 6, 2019), Kathryn J. Kennedy
A Current Update Of Epcrs Through Rev. Proc. 2019-19, 47 Tax Mgmt. Comp. Plan. J. 1 (Dec. 6, 2019), Kathryn J. Kennedy
UIC Law Open Access Faculty Scholarship
No abstract provided.
Tax Policy For The Wider Cryptoverse, Arild B. Doerge
Tax Policy For The Wider Cryptoverse, Arild B. Doerge
Student Scholarship
The rapid rise of Bitcoin and other “cryptoassets” offers many interesting technological capabilities but also comes with uncertainty and volatility in the markets for these assets. The diversity of types of cryptoassets is increasing rapidly, while public understanding and government policy have generally been slow to take account of this diversity. In regard to taxation policy related to cryptoassets, current IRS guidance merely categorizes cryptoassets as general property. The policy implications of this classification run contrary to fundamental goals of tax policy by inhibiting how people use cryptoassets, making compliance more complex and ambiguous than necessary, and taxing cryptoasset transactions …
Unregulated Charity, Eric Franklin Amarante
Unregulated Charity, Eric Franklin Amarante
Washington Law Review
The vast majority of charities in the United States operate in a regulatory blind spot: they are neither meaningfully evaluated when they apply for charitable status nor substantively monitored after they receive charitable status. Driven by severe budget constraints, the IRS decided to essentially ignore any charity that claims it will realize less than $50,000 in annual gross receipts. From a practical perspective, the IRS’s decision makes sense. To the extent smaller charities are less likely to cause harm, it is reasonable (perhaps even preferable) to subject them to less scrutiny. This type of prioritization, known as risk-based regulation, has …
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Buffalo Law Review
No abstract provided.
It’S All About The Drd, What’S Wrong With Foreign Branches, And A Few Other Things You Should Know About The New International Tax Provisions, Rebecca Rosenberg
It’S All About The Drd, What’S Wrong With Foreign Branches, And A Few Other Things You Should Know About The New International Tax Provisions, Rebecca Rosenberg
Loyola of Los Angeles Law Review
This Article highlights and analyzes some important points about the new international tax rules. For example, such provisions do not create an entirely territorial system. The partial movement towards territorial objectives is accomplished largely through the new 100% dividends received deduction (DRD) for certain foreign dividends from foreign corporations. However, this new DRD is much more limited in its application than most taxpayers may realize (for example, due to a very long holding period requirement). Even when the DRD potentially applies, taxpayers may attempt to claim foreign tax credits instead.
In addition, some of the new tax provisions show a …
Tax Attorneys As Defenders Of Taxpayer Rights, Michelle Lyon Drumbl
Tax Attorneys As Defenders Of Taxpayer Rights, Michelle Lyon Drumbl
Scholarly Articles
What is the modern role of a tax practitioner, in particular a tax attorney, in the United States? In an era in which the Internal Revenue Service (IRS) is underfunded, understaffed, and struggles to address its mission, tax attorneys play an important role as advocates for taxpayer rights.
Tax attorneys act as advocates who represent ordinary individual taxpayers in controversies with the IRS. These controversies include post-filing disputes, such as audits, as well as issues arising with the collection of assessed taxes. Many of these cases are resolved at the administrative level; those that cannot be resolved are litigated, most …
A Tax On The Clones: The Strange Case Of Bitcoin Cash, Eric D. Chason
A Tax On The Clones: The Strange Case Of Bitcoin Cash, Eric D. Chason
Faculty Publications
No abstract provided.
Table Of Contents, Seattle University Law Review
Table Of Contents, Seattle University Law Review
Seattle University Law Review
No abstract provided.
Toward Fair And Sustainable Capitalism: A Comprehensive Proposal To Help American Workers, Restore Fair Gainsharing Between Employees And Shareholders, And Increase American Competitiveness By Reorienting Our Corporate Governance System Toward Sustainable Long-Term Growth And Encouraging Investments In America’S Future, Leo E. Strine Jr.
All Faculty Scholarship
To promote fair and sustainable capitalism and help business and labor work together to build an American economy that works for all, this paper presents a comprehensive proposal to reform the American corporate governance system by aligning the incentives of those who control large U.S. corporations with the interests of working Americans who must put their hard-earned savings in mutual funds in their 401(k) and 529 plans. The proposal would achieve this through a series of measured, coherent changes to current laws and regulations, including: requiring not just operating companies, but institutional investors, to give appropriate consideration to and make …
A Tax Hike Liberals And Conservatives Should Both Like, Nathan B. Oman
A Tax Hike Liberals And Conservatives Should Both Like, Nathan B. Oman
Nathan B. Oman
No abstract provided.
Why Pension Funding Matters, Eric D. Chason
The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason
The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason
Eric D. Chason
No abstract provided.
Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason
Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason
Eric D. Chason
No abstract provided.
Executive Compensation And Tax Neutrality: Taxing The Investment Component Of Deferred Compensation, Eric D. Chason
Executive Compensation And Tax Neutrality: Taxing The Investment Component Of Deferred Compensation, Eric D. Chason
Eric D. Chason
No abstract provided.
Deferred Compensation Reform: Taxing The Fruit Of The Tree In Its Proper Season, Eric D. Chason
Deferred Compensation Reform: Taxing The Fruit Of The Tree In Its Proper Season, Eric D. Chason
Eric D. Chason
Executive pensions (or deferred compensation) grabbed headlines after Enron's collapse and fresh concerns over ever-increasing executive pay. They also grabbed the attention of Congress, which reformed executive pensions legislatively in 2004 with § 409A of the Internal Revenue Code. Section 409A merely tightens and clarifies the doctrines that had already governed executive pensions, leaving the basic economics of executive pensions unchanged. Executives can still defer taxation on current compensation until actual payment is made in the future. Deferral still comes at the same price to the employer, namely the deferral of its deduction for the compensation expense. Thus, the timing …
Extending The Taxation-Of-Risk Model To Timing Options And Marked-To-Market Taxes, Eric D. Chason
Extending The Taxation-Of-Risk Model To Timing Options And Marked-To-Market Taxes, Eric D. Chason
Eric D. Chason
No abstract provided.
Law School News: Remembering Rwu Laws Founding Dean 9-10-2019, Roger Williams University School Of Law
Law School News: Remembering Rwu Laws Founding Dean 9-10-2019, Roger Williams University School Of Law
Life of the Law School (1993- )
No abstract provided.
Mormon Profit: Brigham Young, Tithing, And The Bureau Of Internal Revenue, Samuel D. Brunson
Mormon Profit: Brigham Young, Tithing, And The Bureau Of Internal Revenue, Samuel D. Brunson
BYU Law Review
No abstract provided.
Fun Tax Facts, Rachana Khandelwal
Roger Cpa Review Questions, Roger Philipp Cpa, Cgma
Roger Cpa Review Questions, Roger Philipp Cpa, Cgma
The Contemporary Tax Journal
No abstract provided.
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress), Langzun Li
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress), Langzun Li
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.)
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones, Inna Ostrovsky
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones, Inna Ostrovsky
The Contemporary Tax Journal
No abstract provided.
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute, Chen Chen, Liwei Bi, Surbhi Doshi
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute, Chen Chen, Liwei Bi, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
Summaries From The 34th Annual High Tech Tax Institute, Amy Yue Cpa, Langzun Li, Rachana Khandelwal, Nam Nguyen
Summaries From The 34th Annual High Tech Tax Institute, Amy Yue Cpa, Langzun Li, Rachana Khandelwal, Nam Nguyen
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill, Surbhi Doshi
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019
The Contemporary Tax Journal
No abstract provided.
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018, Inna Ostrovsky, Joanna Levasseur
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018, Inna Ostrovsky, Joanna Levasseur
The Contemporary Tax Journal
No abstract provided.
Foreword, Michelle Lyon Drumbl
Foreword, Michelle Lyon Drumbl
Washington and Lee Journal of Civil Rights and Social Justice
Michelle L. Drumbl, Clinical Professor of Law and Director of the Tax Clinic at W&L Law, introduces this issue of the Journal of Civil Rights and Social Justice, which includes material presented at and inspired by the Journal's 2018 symposium, Always with Us? Poverty, Taxes, and Social Policy.