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Articles 1 - 30 of 30
Full-Text Articles in Law
Tax Lawyers As Tax Insurance, Heather M. Field
Tax Lawyers As Tax Insurance, Heather M. Field
William & Mary Law Review
Transactional tax lawyers, by rendering tax opinions, provide a version of insurance to clients. This insurance is clearly incomplete, but by providing a tax opinion, a lawyer conditionally agrees to indemnify the client for at least part of the potential loss the client incurs if the favorable tax treatment described in the opinion is successfully challenged. Although insurance is not the primary function of transactional tax lawyers, and although this Article does not argue that tax opinions should be regulated as insurance, indemnification—a key element of insurance—is an important part of the economic relationship between a client and a lawyer …
Recent Developments In Virginia Taxation, Craig D. Bell
Recent Developments In Virginia Taxation, Craig D. Bell
William & Mary Annual Tax Conference
No abstract provided.
A Historical Examination Of The Constitutionality Of The Federal Estate Tax, Henry Lowenstein, Kathryn Kisska-Schulze
A Historical Examination Of The Constitutionality Of The Federal Estate Tax, Henry Lowenstein, Kathryn Kisska-Schulze
William & Mary Bill of Rights Journal
No abstract provided.
Understanding Section 704(C) (Powerpoint), Brian J. O'Connor
Understanding Section 704(C) (Powerpoint), Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Recent Tax Developments In Virginia: 2015-2016, Craig D. Bell, William L.S Rowe, Emily J. Winbigler
Recent Tax Developments In Virginia: 2015-2016, Craig D. Bell, William L.S Rowe, Emily J. Winbigler
William & Mary Annual Tax Conference
No abstract provided.
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 …
Negotiating Tax Provisions In Partnership And Llc Agreements, Robert G. Gottlieb, Brian J. O'Connor
Negotiating Tax Provisions In Partnership And Llc Agreements, Robert G. Gottlieb, Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen
Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen
William & Mary Annual Tax Conference
No abstract provided.
Tax Accounting Methods Considerations In Restructuring Transactions, Glenn Carrington, Kristine Mora
Tax Accounting Methods Considerations In Restructuring Transactions, Glenn Carrington, Kristine Mora
William & Mary Annual Tax Conference
No abstract provided.
Advising Estate Planning Clients After The 2012 Tax Act, Dennis I. Belcher, Charles D. Fox Iv
Advising Estate Planning Clients After The 2012 Tax Act, Dennis I. Belcher, Charles D. Fox Iv
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments & Tax Planning For High Income Taxpayers, Cameron N. Cosby, Brian J. O'Connor
Recent Developments & Tax Planning For High Income Taxpayers, Cameron N. Cosby, Brian J. O'Connor
William & Mary Annual Tax Conference
No abstract provided.
The Economic Ambiguity (And Possible Irrelevance) Of Tax Transition Rules, Eric D. Chason
The Economic Ambiguity (And Possible Irrelevance) Of Tax Transition Rules, Eric D. Chason
Faculty Publications
No abstract provided.
Corporate Managers, Agency Costs, And The Rise Of Double Taxation, Steven A. Bank
Corporate Managers, Agency Costs, And The Rise Of Double Taxation, Steven A. Bank
William & Mary Law Review
No abstract provided.
"Tax Library" Resources For The Small To Medium Sized Cpa Or Law Firm - Roundtable Discussion, Michael L. Layman, Timothy H. Guare, J. Patrick Budd, Gregory W. Geisert
"Tax Library" Resources For The Small To Medium Sized Cpa Or Law Firm - Roundtable Discussion, Michael L. Layman, Timothy H. Guare, J. Patrick Budd, Gregory W. Geisert
William & Mary Annual Tax Conference
No abstract provided.
Recent Tax Developments In Virginia, William L.S. Rowe
Recent Tax Developments In Virginia, William L.S. Rowe
William & Mary Annual Tax Conference
No abstract provided.
Who Should Be Entitled To Claim The New Education Credits?, Glenn E. Coven
Who Should Be Entitled To Claim The New Education Credits?, Glenn E. Coven
Faculty Publications
Professor Coven believes that the education assistance provisions enacted in 1997, while long overdue, were ill-considered and poorly constructed. Focusing on what should have been the simple question of who is entitled to claim an education tax credit, this report illustrates the harm that inadequate drafting produces. While section 25A appeared to deny a credit to a dependent child, an unfair and unwise result, the proposed regulations allow parents to shift the credit to their children but only on the forfeiture of the deduction for the personal exemption. That rule, says Coven, imposes a harsh penalty on low and middle-income …
Selected Recent Federal Income Tax Developments, Ira B. Shepard
Selected Recent Federal Income Tax Developments, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Ethical Problems In Tax Practice, L. Paige Marvel, Paula M. Junghans
Ethical Problems In Tax Practice, L. Paige Marvel, Paula M. Junghans
William & Mary Annual Tax Conference
No abstract provided.
Recent Federal Income Tax Developments, Ira B. Shepard
Recent Federal Income Tax Developments, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Recent Tax Developments In Virginia, William L.S. Rowe
Recent Tax Developments In Virginia, William L.S. Rowe
William & Mary Annual Tax Conference
No abstract provided.
Simplified Entity Classification Under The Final Check-The-Box Regulations, Roger F. Pillow, John G. Schmalz, Samuel P. Starr
Simplified Entity Classification Under The Final Check-The-Box Regulations, Roger F. Pillow, John G. Schmalz, Samuel P. Starr
William & Mary Annual Tax Conference
No abstract provided.
Tax Issues In Divorce, Marjorie A. O'Connell
Tax Issues In Divorce, Marjorie A. O'Connell
William & Mary Annual Tax Conference
No abstract provided.
Incriminatory Effects Of Compliance With Irs Subpoenas For Personal Documents: An Analysis Of Current Approaches, Leah A. Kahl
Incriminatory Effects Of Compliance With Irs Subpoenas For Personal Documents: An Analysis Of Current Approaches, Leah A. Kahl
William & Mary Bill of Rights Journal
This Note argues that creating a tax-crime exception to the privilege against self-incrimination countervenes both the language and the spirit of the Fifth Amendment. This Note further argues that the Ninth Circuit's creation of a tax crime-exception stemmed from a misinterpretation of precedent.
This Note describes the tax system and structure of the Internal Revenue Service (IRS), including its investigatory powers. The relationship between the IRS and the Department of Justice is discussed to ascertain the incriminatory effects of taxpayers' disclosures. A Ninth Circuit district court case, United States v. Troescher, is used as a framework for analyzing the Ninth …
The Year In Review: A Discussion Of Significant Regulations, Rulings And Cases, Stefan F. Tucker
The Year In Review: A Discussion Of Significant Regulations, Rulings And Cases, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Professional Responsibility: Beyond Pure Ethics And Circular 230 (Outline), Leslie S. Shapiro
Professional Responsibility: Beyond Pure Ethics And Circular 230 (Outline), Leslie S. Shapiro
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments In Federal Income Taxation, Ira B. Shepard
Recent Developments In Federal Income Taxation, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Tax Court Decision Unsettles Irs Subchapter S Procedures, Glenn E. Coven
Tax Court Decision Unsettles Irs Subchapter S Procedures, Glenn E. Coven
Faculty Publications
No abstract provided.
Making Subchapter S Work, Glenn E. Coven
Tax Policy Analysis Of Bob Jones University V. U.S, Charles O. Galvin, Neal Devins
Tax Policy Analysis Of Bob Jones University V. U.S, Charles O. Galvin, Neal Devins
Faculty Publications
No abstract provided.
Standing To Challenge Tax Treatment Of Competitors
Standing To Challenge Tax Treatment Of Competitors
William & Mary Law Review
No abstract provided.