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Articles 1 - 30 of 39
Full-Text Articles in Law
Ground Zero: The Irs Attack On Syndicated Conservation Easements, Beckett G. Cantley, Geoffrey C. Dietrich
Ground Zero: The Irs Attack On Syndicated Conservation Easements, Beckett G. Cantley, Geoffrey C. Dietrich
William & Mary Environmental Law and Policy Review
On June 25, 2020, the Internal Revenue Service (“IRS”) announced a settlement initiative (“SI”) to certain taxpayers with pending docketed cases involving syndicated conservation easement (“SCE”) transactions. The SI is the current culmination of a long series of attacks by the IRS against SCE transactions. The IRS has recently found success in the Tax Court against SCEs, but the agency’s overall legal position may be overstated. It is possible that the recent SI is merely an attempt to capitalize on leverage while the IRS has it. Regardless, the current state of the law surrounding SCEs is murky at best. Whether …
Reforming The Charitable Contribution Tax Deduction: Accounting For Random Acts Of Charity, Janene R. Finley
Reforming The Charitable Contribution Tax Deduction: Accounting For Random Acts Of Charity, Janene R. Finley
William & Mary Business Law Review
Concern for the tax treatment of charitable contributions has increased as a result of the Tax Cuts and Jobs Act of 2017. Although the new law increased the limitation of deductible charitable contributions to 60 percent of adjusted gross income, the standard deduction was also increased. Increasing the standard deduction is expected to reduce the number of taxpayers who are able to itemize their deductions in the next tax year, which is expected to reduce charitable giving in the future. This Article discusses proposals to amend the Internal Revenue Code to promote charitable giving, including a non-itemizer deduction. In addition, …
Permitting Abused Spouses To Claim The Earned Income Tax Credit In Separate Returns, Fred B. Brown
Permitting Abused Spouses To Claim The Earned Income Tax Credit In Separate Returns, Fred B. Brown
William & Mary Journal of Race, Gender, and Social Justice
No abstract provided.
The Enigma Of Wynne, Edward A. Zelinsky
The Enigma Of Wynne, Edward A. Zelinsky
William & Mary Business Law Review
The five-justice Wynne majority used that case to make a major statement about the dormant Commerce Clause. In many respects, Wynne is an enigma that perpetuates an inherent problem of the Courts dormant Commerce Clause doctrine: the Court declares some ill-defined taxes as unconstitutionally discriminatory because they encourage in-state investment, while other economically equivalent taxes and government programs that similarly encourage intrastate economic activity are apparently acceptable under the dormant Commerce Clause.
Wynne is thus more important than the immediate situation it addresses, and will have consequences beyond the immediate circumstances it addresses. A decision as enigmatic as it is …
Basing Budget Baselines, David Kamin
Basing Budget Baselines, David Kamin
William & Mary Law Review
Measuring the cost of legislation or even projecting the course of the federal budget requires defining a budget baseline—a starting point capturing the current state of the budget. Budget baselines underlie most measures employed in federal budget debates and enforcement rules. Yet, despite their widespread use, budget baselines engender considerable confusion and abuse.
For instance, when legislators enact temporary tax breaks, the breaks are officially estimated to cost far less than they likely will because of a loophole in federal budget baseline rules. Then, later efforts to extend the tax cuts are counted as increasing deficits when, in fact, by …
Taxation, Pregnancy, And Privacy, Bridget J. Crawford
Taxation, Pregnancy, And Privacy, Bridget J. Crawford
William & Mary Journal of Race, Gender, and Social Justice
This Article frames a discussion of surrogacy within the context of existing income tax laws. A surrogate receives money for carrying and bearing a child. This payment is income by any definition, even if the surrogacy contract recites that it is a “reimbursement.” Cases and rulings on the income tax consequences of the sale of blood and human breast milk, as well as analogies to situations in which people are paid to wear advertising on their bodies, support the conclusion that a surrogate recognizes taxable income, although the Internal Revenue Service has never stated so. For tax purposes, the reproductive …
The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll
The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll
William & Mary Law Review
In this Article, I estimate the tax revenue effects of taxing private equity carried interests as ordinary income rather than as long-term capital gain as under current law. Under reasonable assumptions, I conclude that the expected present value of additional tax collections would be between 1 percent and 1.5 percent of capital invested in private equity funds, or between $2 billion and $3 billion a year. That estimate, however, makes no allowance for changes in the structure of such funds or the composition of the partnerships, which might substantially reduce tax revenues below those estimates.
Congress's Tax Incentives Send Mixed Signals For Automobile Buyers: Should Americans Buy Gas Guzzlers Or Hybrids?, Bradley A. Ridlehoover
Congress's Tax Incentives Send Mixed Signals For Automobile Buyers: Should Americans Buy Gas Guzzlers Or Hybrids?, Bradley A. Ridlehoover
William & Mary Environmental Law and Policy Review
No abstract provided.
The Effects Of The Virginia Land Preservation Credit On Federal Taxable Income: Should The Right Hand Take From What The Left Hand Gave?, W. Eugene Seago
The Effects Of The Virginia Land Preservation Credit On Federal Taxable Income: Should The Right Hand Take From What The Left Hand Gave?, W. Eugene Seago
William & Mary Environmental Law and Policy Review
No abstract provided.
Entity Theory As Myth In The Origins Of The Corporate Income Tax, Steven A. Bank
Entity Theory As Myth In The Origins Of The Corporate Income Tax, Steven A. Bank
William & Mary Law Review
No abstract provided.
A Historical Essay And Economic Assay Of The Capital Asset Definition: The Taxpayer And Courts Are Still Mindfully Guessing While Congress Doesn't Seem To (Have A) Mind, Joseph Byron Cartee
A Historical Essay And Economic Assay Of The Capital Asset Definition: The Taxpayer And Courts Are Still Mindfully Guessing While Congress Doesn't Seem To (Have A) Mind, Joseph Byron Cartee
William & Mary Law Review
No abstract provided.
Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer
Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer
William & Mary Law Review
No abstract provided.
Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status
Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status
William & Mary Law Review
No abstract provided.
The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott
The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott
William & Mary Law Review
No abstract provided.
Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson
Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson
William & Mary Law Review
No abstract provided.
Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr.
Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr.
William & Mary Law Review
No abstract provided.
Tax Planning For The Not-So-Rich: Variable And Private Annuities, Anthony M. Vernava
Tax Planning For The Not-So-Rich: Variable And Private Annuities, Anthony M. Vernava
William & Mary Law Review
No abstract provided.
Federal Taxation - Accumulated Earnings Tax - The Quantum Of Tax Avoidance Purpose Required - United States V. Donruss, 89 S. Ct. 501 (1969), Robert S. Parker Jr.
Federal Taxation - Accumulated Earnings Tax - The Quantum Of Tax Avoidance Purpose Required - United States V. Donruss, 89 S. Ct. 501 (1969), Robert S. Parker Jr.
William & Mary Law Review
No abstract provided.
Federal Taxation - Professional Service Corporation - Corporate Versus Partnership Statute - Empey V. United States, __ F. 2d __ (10th Cir. 1969)., Haldane Robert Mayer
Federal Taxation - Professional Service Corporation - Corporate Versus Partnership Statute - Empey V. United States, __ F. 2d __ (10th Cir. 1969)., Haldane Robert Mayer
William & Mary Law Review
No abstract provided.
Non-Business Guaranty Loss: Ordinary Or Capital Deduction, Robert S. Parker Jr.
Non-Business Guaranty Loss: Ordinary Or Capital Deduction, Robert S. Parker Jr.
William & Mary Law Review
No abstract provided.
Book Review Of Items Of Gross Income, Emeric Fischer
Book Review Of Items Of Gross Income, Emeric Fischer
William & Mary Law Review
No abstract provided.
The Treatment Of Income & Deductions In The Case Of Controlled Or Related Entities, William H. Westphal
The Treatment Of Income & Deductions In The Case Of Controlled Or Related Entities, William H. Westphal
William & Mary Law Review
No abstract provided.
The Reincorporation Problem In Subchapter C. A Question Of Semantics?, R. P. Hertzog
The Reincorporation Problem In Subchapter C. A Question Of Semantics?, R. P. Hertzog
William & Mary Law Review
No abstract provided.
Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen
Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen
William & Mary Law Review
No abstract provided.
Simplification And Equity As Goals Of Tax Policy, Stanley S. Surrey, Gerard M. Brannon
Simplification And Equity As Goals Of Tax Policy, Stanley S. Surrey, Gerard M. Brannon
William & Mary Law Review
No abstract provided.
Tax Legislation Of 1966, John E. Donaldson
Tax Legislation Of 1966, John E. Donaldson
William & Mary Law Review
No abstract provided.
Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer
Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer
William & Mary Law Review
No abstract provided.
Federal Taxation - Depreciation Of Assets In The Year Of Disposal
Federal Taxation - Depreciation Of Assets In The Year Of Disposal
William & Mary Law Review
No abstract provided.
The New "Subpart F" Foreign Income Provisions Of The Internal Revenue Code, Rexford R. Cherryman
The New "Subpart F" Foreign Income Provisions Of The Internal Revenue Code, Rexford R. Cherryman
William & Mary Law Review
No abstract provided.
The Reconstruction Of Net Income Under § 446(B) Of The Internal Revenue Code, John J. Harrington
The Reconstruction Of Net Income Under § 446(B) Of The Internal Revenue Code, John J. Harrington
William & Mary Law Review
No abstract provided.