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Articles 1 - 29 of 29
Full-Text Articles in Law
Simplexity: Plain Language And The Tax Law, Joshua D. Blank, Leigh Osofsky
Simplexity: Plain Language And The Tax Law, Joshua D. Blank, Leigh Osofsky
Articles
In recent years, federal government agencies have increasingly attempted to use plain language in written communications with the public. The Plain Writing Act of 2010, for instance, requires agencies to incorporate "clear and simple" explanations of rules and regulations into their official publications. In the tax context, as part of its "customer service" mission, the Internal Revenue Service bears a "duty to explain" the tax law to hundreds of millions of taxpayers who file tax returns each year. Proponents of the plain language movement have heralded this form of communication as leading to simplicity in tax compliance, more equitable access …
Dark Money In Motion: Mapping Issues Along The Money Trail, Frances R. Hill
Dark Money In Motion: Mapping Issues Along The Money Trail, Frances R. Hill
Articles
No abstract provided.
The Case For Categorical Nonenforcement, Leigh Osofsky
Distinguishing Deductible Repairs From Capitalized Improvements: An Expectations Approach To The New Repair Regulations, George Mundstock, Thomas J. Korge
Distinguishing Deductible Repairs From Capitalized Improvements: An Expectations Approach To The New Repair Regulations, George Mundstock, Thomas J. Korge
Articles
No abstract provided.
Unwinding The Ceiling Rule, Leigh Osofsky
Unwinding The Ceiling Rule, Leigh Osofsky
Articles
This article closely examines the unwinding of the ceiling rule. Congress and partnership tax experts historically have assumed perfect unwinding of the ceiling rule on liquidation or sale of a partnership interest. However, this assumption glosses over a significantly more complicated reality. This article closely examines the history of section 704(c) and the interaction between the ceiling rule and the rules regarding sales and liquidations of partnership interests to reveal the extent to which the assumption does not hold. By debunking long-held assumptions about the perfect unwinding of the ceiling rule, this article displays that there is no reasonable justification …
What Makes A Dutch Company Dutch? The Evolution Of Us Limitation-On-Benefits Provisions, Patricia A. Brown
What Makes A Dutch Company Dutch? The Evolution Of Us Limitation-On-Benefits Provisions, Patricia A. Brown
Articles
No abstract provided.
Citizens United And Social Welfare Organizations: The Tangled Relationships Among Guidance, Compliance, And Enforcement, Frances R. Hill
Citizens United And Social Welfare Organizations: The Tangled Relationships Among Guidance, Compliance, And Enforcement, Frances R. Hill
Articles
No abstract provided.
Who's Naughty And Who's Nice? Frictions, Screening, And Tax Law Design, Leigh Osofsky
Who's Naughty And Who's Nice? Frictions, Screening, And Tax Law Design, Leigh Osofsky
Articles
No abstract provided.
Exempt Entities As Government Contractors: Regulation Through Cooperative Federalism, Frances R. Hill
Exempt Entities As Government Contractors: Regulation Through Cooperative Federalism, Frances R. Hill
Articles
No abstract provided.
Some Realism About Responsive Tax Administration, Leigh Osofsky
Some Realism About Responsive Tax Administration, Leigh Osofsky
Articles
No abstract provided.
Online Retailers' Tax-Free Lunches, George Mundstock
The Case Against Strategic Tax Law Uncertainty, Leigh Osofsky
The Case Against Strategic Tax Law Uncertainty, Leigh Osofsky
Articles
No abstract provided.
Cognitive Capture, Parliamentary Parentheses, And The Rise Of Fractional Apportionment, Stanley I. Langbein
Cognitive Capture, Parliamentary Parentheses, And The Rise Of Fractional Apportionment, Stanley I. Langbein
Articles
No abstract provided.
Wealth Is Just Capital!, George Mundstock
Targeting Exemption For Charitable Efficiency: Designing A Nondiversion Constraint, Frances R. Hill
Targeting Exemption For Charitable Efficiency: Designing A Nondiversion Constraint, Frances R. Hill
Articles
No abstract provided.
United States -- Tax Treatment For "Foreign Sales Corporations" Wto Doc. Wt/Ds108/Ab/R, Stanley I. Langbein
United States -- Tax Treatment For "Foreign Sales Corporations" Wto Doc. Wt/Ds108/Ab/R, Stanley I. Langbein
Articles
No abstract provided.
Minority Discounts, Fair Market Value, And The Culture Of Estate Taxation, William S. Blatt
Minority Discounts, Fair Market Value, And The Culture Of Estate Taxation, William S. Blatt
Articles
No abstract provided.
The American Dream In Legislation: The Role Of Popular Symbols In Wealth Tax Policy, William S. Blatt
The American Dream In Legislation: The Role Of Popular Symbols In Wealth Tax Policy, William S. Blatt
Articles
No abstract provided.
Section 902 Is Too Generous, George Mundstock
Taxation Of Business Rent, George Mundstock
Lost On A One-Way Street: The Taxpayer's Ability To Disavow Form, William S. Blatt
Lost On A One-Way Street: The Taxpayer's Ability To Disavow Form, William S. Blatt
Articles
No abstract provided.
The Direct Investment Tax Initiatives Of The European Community: A View From The United States, Stanley I. Langbein, David H. Rosenbloom
The Direct Investment Tax Initiatives Of The European Community: A View From The United States, Stanley I. Langbein, David H. Rosenbloom
Articles
No abstract provided.
The Low-Income Housing Tax Credit: A Poor Solution To The Housing Crisis, Janet Stearns
The Low-Income Housing Tax Credit: A Poor Solution To The Housing Crisis, Janet Stearns
Articles
No abstract provided.
Taxation Of Business Intangible Capital, George Mundstock
Taxation Of Business Intangible Capital, George Mundstock
Articles
No abstract provided.
The Federal Circuit's 1985 Tax Cases: The Exercise Of Equity, William S. Blatt
The Federal Circuit's 1985 Tax Cases: The Exercise Of Equity, William S. Blatt
Articles
No abstract provided.
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Articles
No abstract provided.
An Essay On The Conceptual Foundations Of The Tax Benefit Rule, Patricia D. White
An Essay On The Conceptual Foundations Of The Tax Benefit Rule, Patricia D. White
Articles
A good deal has been written over the past forty-odd years about the tax benefit rule. Over this period the federal courts have decided many cases in which its application has been at issue, and the law journals have published a small but steady stream of commentary on the rule and its manifestations. Last term, in Hillsboro National Bank v. Commissioner, the Supreme Court issued an opinion that focused squarely, and at some length, on the tax benefit rule. Despite this attention, relatively little has been done to examine the conceptual foundations of the tax benefit rule and to …
United States Tax Treaty Policy: An Overview, H. David Rosenbloom, Stanley Langbein
United States Tax Treaty Policy: An Overview, H. David Rosenbloom, Stanley Langbein
Articles
No abstract provided.
Extracting Documents And Information From The Internal Revenue Service, Stuart E. Siegel, Stanley I. Langbein
Extracting Documents And Information From The Internal Revenue Service, Stuart E. Siegel, Stanley I. Langbein
Articles
No abstract provided.