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Full-Text Articles in Law
I.R.C. § 302(B)(1): Dividend Equivalency After United States V. Davis, Ronald L. Nelson
I.R.C. § 302(B)(1): Dividend Equivalency After United States V. Davis, Ronald L. Nelson
Florida State University Law Review
No abstract provided.
The Haitian Vacation: The Applicability Of Sham Doctrine To Year-End Divorces, Michigan Law Review
The Haitian Vacation: The Applicability Of Sham Doctrine To Year-End Divorces, Michigan Law Review
Michigan Law Review
This Note examines the propriety of applying the sham doctrine to tax-motivated divorces. Section I outlines the evolution of the sham doctrine from its exposition in Gregory v. Helvering through its expression in two different tests for commercial transactions. Section II then studies the relationship between state divorce law and the marital status provisions of the Internal Revenue Code to demonstrate the clear congressional preference for incorporating state law by reference rather than creating an independent federal law of marriage. It also examines the history of the 1969 Tax Reform Act in a vain effort to discern a congressional desire …
Taxation Of Foreign-Earned Income In Kind: Henry Taxpayer Goes To Japan, Carole Silver Adler
Taxation Of Foreign-Earned Income In Kind: Henry Taxpayer Goes To Japan, Carole Silver Adler
Indiana Law Journal
No abstract provided.
Capital Gains And Losses: A Primer (Part Two), Thomas J. Gallagher, Jr.
Capital Gains And Losses: A Primer (Part Two), Thomas J. Gallagher, Jr.
Florida State University Law Review
No abstract provided.
Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr.
Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr.
Florida State University Law Review
No abstract provided.
Accelerated Depreciation—Tax Expenditure Or Proper Allowance For Measuring Net Income?, Douglas A. Kahn
Accelerated Depreciation—Tax Expenditure Or Proper Allowance For Measuring Net Income?, Douglas A. Kahn
Articles
Since the 1950s, it has become fashionable to attack various provisions of the Internal Revenue Code by calling them "subsidies" rather than "proper" means of measuring taxable income. These "subsidies" through Code provisions have come to be referred to as "tax expenditures," a term coined by Professor Stanley Surrey in a speech he made as Assistant Secretary of the Treasury for Tax Policy on November 15, 1967. In that speech, Professor Surrey stated that our tax system often deliberately departs "from accepted concepts of net income," so that by granting exemptions, deductions, and credits that are not appropriate to an …