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Deconstructing The Rules Of Corporate Tax, Rachelle Y. Holmes
Deconstructing The Rules Of Corporate Tax, Rachelle Y. Holmes
Akron Tax Journal
While academics, practitioners, and the White House have proposed any number of reform measures to deal with the problems plaguing the U.S. corporate tax regime, their solutions involve varying structural and statutory changes, which are in fact extrinsic to the form of the underlying rules themselves. In contrast, this Article argues for an innate form of change to the U.S. corporate tax rules, which would fundamentally affect the way in which tax lawmakers actually draft tax rules and regulations. In particular, it argues that a systemic focus and commitment by lawmakers to a more principles-based approach to regulation would significantly …
The Importance Of Being Interest: Why A State Cannot Impose Its Income Tax On Tribal Bonds, Scott A. Taylor
The Importance Of Being Interest: Why A State Cannot Impose Its Income Tax On Tribal Bonds, Scott A. Taylor
Akron Tax Journal
In order to provide the fullest consideration of these very complicated issues, I have divided my discussion into six parts. In the first part, I discuss specific state statutes to show how their application to the state income taxation of interest on tribal bonds is textually unclear. The primary purpose of this part of the discussion is to show that the analysis must start with the particular state income tax statute itself to see if it purports to tax the interest income generated by a tribal bond. In some instances, the more reasonable interpretation of the state statute may lead …