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Full-Text Articles in Law
Words Of Wisdom From The Founding Fathers: Why The Internal Revenue Service Should Let Churches Be, Sophia Benavides
Words Of Wisdom From The Founding Fathers: Why The Internal Revenue Service Should Let Churches Be, Sophia Benavides
Journal of the National Association of Administrative Law Judiciary
Part I of this comment will explore the foundations of the First Amendment, as the Constitution is a framework on which the United States continues to rest. An examination of the events contributing and leading to the drafting of the Constitution will illuminate the rationale behind the tenets put forth by the Founding Fathers. More specifically, this comment will devote emphasis to the Founding Fathers’ objectives regarding the state in relation to religion. This emphasis will provide insight into the perspective of the Founders at the time of drafting the First Amendment. Furthermore, this section will illustrate how the separation …
Reinvigorating The Reit's Neutrality And Capital Formation Purposes Through A Modernized Tax Integration Model, Simon Johnson
Reinvigorating The Reit's Neutrality And Capital Formation Purposes Through A Modernized Tax Integration Model, Simon Johnson
The Journal of Business, Entrepreneurship & the Law
Efforts at reform have not spared the REIT arrangement, but have focused on objectives unrelated to its model of tax integration, despite its significant flaws. Owing to the interaction of several provisions, the model largely precludes capitalization through retained earnings. This increases the cost of REIT capital and limits its capacity to realize the neutrality and private real estate capital formation objectives Congress pursued in creating the arrangement. Accordingly, it is important to consider how to durably improve the REIT tax integration model. Ultimately, the article concludes that the shareholder allocation model, a complete integration model conceptually similar to the …
Putting The Reign Back In Sovereign, Allison Christians
Putting The Reign Back In Sovereign, Allison Christians
Pepperdine Law Review
In its first term, the Obama administration enacted two pieces of legislation, each designed to protect an increasingly vulnerable income tax base, and each of which had the potential to set a new and unprecedented course for no less than the regulation of the global economy by the nation-state. The first, the Foreign Account Tax Compliance Act (FATCA), sought to end global tax evasion through tax havens. The second, a little-noticed two-page addendum to the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), sought to end the contribution of American multinationals to corruption in governance by codifying the transparency …
Administrative Savings From Synchronizing Social Welfare Programs And Tax Provisions, Jonathan Barry Forman
Administrative Savings From Synchronizing Social Welfare Programs And Tax Provisions, Jonathan Barry Forman
Journal of the National Association of Administrative Law Judiciary
No abstract provided.
Horse Syndication: A Sure Footed Winner In The Investment Sweepstakes, Thomas R. Catanese
Horse Syndication: A Sure Footed Winner In The Investment Sweepstakes, Thomas R. Catanese
Pepperdine Law Review
Recent changes in the scheme of federal taxation coupled with increasing interest in the equine industry has propelled that industry into the forefront of tax sheltered investments. In this article the author takes an in-depth look at the federal securities and tax law aspects of a typical equine syndication as a tax sheltered investment.
Indopco, Inc. V. Commissioner: National Starch Isn't The Only One "Stiffed" By The Supreme Court's Decision, Jeffrey Gates Davis
Indopco, Inc. V. Commissioner: National Starch Isn't The Only One "Stiffed" By The Supreme Court's Decision, Jeffrey Gates Davis
Pepperdine Law Review
No abstract provided.