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Articles 1 - 6 of 6
Full-Text Articles in Law
For Realization: Income Taxation, Sectoral Accretionism, And The Virtue Of Attainable Virtues, Edward A. Zelinsky
For Realization: Income Taxation, Sectoral Accretionism, And The Virtue Of Attainable Virtues, Edward A. Zelinsky
Articles
No abstract provided.
The Hazards Of Tinkering With The Common Law Of Future Interests: The California Experience, Laura E. Cunningham
The Hazards Of Tinkering With The Common Law Of Future Interests: The California Experience, Laura E. Cunningham
Articles
No abstract provided.
U.S. International Treatment Of Financial Derivatives, Reuven Avi-Yonah, Linda Swartz
U.S. International Treatment Of Financial Derivatives, Reuven Avi-Yonah, Linda Swartz
Articles
The current proposals to substitute consumption for income as the principal U.S. tax base have already been the topic of considerable commentary in these pages. However, one issue has received relatively little attention in the discussion of the various reform proposals: What potential complications are likely to arise if a single major player in the world's economy unilaterally adopts radical tax reform? The global economy is becoming more and more unified, with multinational corporations dominating world trade and trillions of dollars in portfolio investment flowing across national boundaries. In this economy, what would be the consequences if a single country, …
To End Deferral As We Know It: Simplification Potential Of Check-The-Box, Reuven Avi-Yonah
To End Deferral As We Know It: Simplification Potential Of Check-The-Box, Reuven Avi-Yonah
Articles
On December 17, 1996, the Treasury Department issued final regulations under section 7701 of the Internal Revenue Code implementing the regime dubbed "check-the-box," under which taxpayers can elect to be treated as corporations or as passthrough entities for U.S. tax purposes. The purpose of this article is to argue that the adoption of these regulations affords a momentous opportunity for Congress to achieve significant simplification of the notoriously complex U.S. international tax rules. Fundamentally, the adoption of check-the- box means that U.S. taxpayers will be able to elect whether or not their foreign-source active income will enjoy deferral from current …
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.
International Taxation Of Electronic Commerce, Reuven S. Avi-Yonah
International Taxation Of Electronic Commerce, Reuven S. Avi-Yonah
Articles
This article submits proposals for taxing the digital economy on the basis of the benefits and single tax principles.