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Full-Text Articles in Law

The Tao Of The Dao: Taxing An Entity That Lives On A Blockchain, David J. Shakow Aug 2018

The Tao Of The Dao: Taxing An Entity That Lives On A Blockchain, David J. Shakow

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In this report, Shakow explains how a decentralized autonomous organization functions and interacts with the U.S. tax system and presents the many tax issues that these structures raise. The possibility of using smart contracts to allow an entity to operate totally autonomously on a blockchain platform seems attractive. However, little thought has been given to how such an entity can comply with the requirements of a tax system. The DAO, the first major attempt to create such an organization, failed because of a programming error. If successful examples proliferate in the future, tax authorities will face significant problems in getting …


Marginal Rates Under The Tcja, Reed Shuldiner Jun 2018

Marginal Rates Under The Tcja, Reed Shuldiner

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In this report, Shuldiner argues that although the Tax Cuts and Jobs Act appears to offer an across-the board reduction in individual marginal tax rates augmented by an additional 20 percent reduction in rates on unincorporated business income, the situation is significantly more complex.


Was The Amt Effectively Repealed?, Reed Shuldiner Apr 2018

Was The Amt Effectively Repealed?, Reed Shuldiner

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The individual alternative minimum tax (AMT) was a much disliked feature of the tax law prior to the Tax Cuts and Jobs Act (TCJA). Yet, despite repeated promises to repeal the AMT as part of tax reform, the TCJA dropped AMT repeal in favor of increasing the AMT exemption and its phaseout threshold. The question raised by this development is whether the AMT changes should be viewed as yet another stop-gap tweak of the AMT or whether the changes should be viewed as returning the AMT to its roots as a tax on high-income taxpayers using excessive loopholes. In this …