Law Commons^™

Constructive Dividend Doctrine From An Integrationist Perspective, Anthony P. Polito

Akron Tax Journal

A long standing feature of U.S. corporate taxation is a group of doctrinal devices serving to prevent taxpayer attempts to avoid double taxation of corporate earnings. This Article refers to these devices collectively as the constructive dividend doctrine (hereinafter “CDD”) and analyzes the extent to which the CDD ought to be set aside as counterproductive.

This analysis is grounded in contrasting views of the normative tax treatment of corporate enterprise. On the one hand is the perspective in which the double income taxation of corporate income is normative (the “Double Tax Perspective”). The Double Tax Perspective calls for taxation of …

Failing Corporate Tax Transparency And The Immediate Need To Reduce Overburdening Duplicative Tax Reporting Requirements, Ilya A. Lipin

Akron Tax Journal

The benefits to corporate taxpayers from the continuing additions to disclosure requirements have not been obvious. Despite expenditures by corporate taxpayers on compliance, there is evidence that the Service has not been using all of the information it receives from additional disclosure forms.28 Duplicative disclosures of the same or similar tax information that lead to additional costs are of immediate concern to the corporate taxpayer.29 The estimated corporate taxpayers’ compliance tax burden is summarized in Appendix 1. Part II of this article describes in detail key existing reporting requirements such as reportable transaction disclosure statement and Form 8886, disclosure statements …