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Full-Text Articles in Law

The Future Of The New International Tax Regime, Rosanne Altshuler, Fadi Shaheen, Jeffrey Colon, Michael Graetz, Rebecca Kysar, Susan Morse, Daniel Shaviro, Richard Phillips, Danielle Rolfes, David Rosenbloom, Stephen Shay, Steven Dean Jan 2018

The Future Of The New International Tax Regime, Rosanne Altshuler, Fadi Shaheen, Jeffrey Colon, Michael Graetz, Rebecca Kysar, Susan Morse, Daniel Shaviro, Richard Phillips, Danielle Rolfes, David Rosenbloom, Stephen Shay, Steven Dean

Fordham Journal of Corporate & Financial Law

No abstract provided.


The Unjustified Subsidy: Sovereign Wealth Funds The Foreign Sovereign Tax Exemption, Jennifer Bird-Pollan Jan 2012

The Unjustified Subsidy: Sovereign Wealth Funds The Foreign Sovereign Tax Exemption, Jennifer Bird-Pollan

Fordham Journal of Corporate & Financial Law

The taxation of Sovereign Wealth Funds in the United States is outmoded and due for reconsideration. Offering a tax exemption to the billion dollar investment funds owned by foreign governments is both unfair and ineffective. Founded in the principles of sovereign immunity, the foreign sovereign tax exemption, codified in I.R.C. § 892, fails to satisfy the Congressional goals that motivated its creation. This Article explains the current taxation of foreign sovereigns and, by extension, Sovereign Wealth Funds. It then illustrates that the current exemption is simultaneously too broad, providing a tax exemption for activities that are clearly nongovernmental activities, and …


The New Section 1202 Tax-Free Business Sale: Congress Rewards Small Businesses That Survived The Great Recession, Beckett G. Cantley Jan 2012

The New Section 1202 Tax-Free Business Sale: Congress Rewards Small Businesses That Survived The Great Recession, Beckett G. Cantley

Fordham Journal of Corporate & Financial Law

On September 27, 2010, President Barack Obama signed the Creating Small Business Jobs Act of 2010 (“SBJA”) that contains a temporary amendment to Internal Revenue Code (“IRC”) § 1202. The amendment permits original shareholders of eligible corporation stock to sell the stock without being taxed on the sale. The temporary amendment initially only applied to certain stock acquired after the enactment of the SBJA and before January 1, 2011, but the amendment was extended on December 17, 2010 for another year ending January 1, 2012. With the impending sunset of the 15% capital gains rate at the end of 2012, …


An End To The Deadbeat Dad Dilemma? - Puncturing The Paradigm By Allowing A Deduction For Child Support Payments , Reginald Mombrun Jan 2008

An End To The Deadbeat Dad Dilemma? - Puncturing The Paradigm By Allowing A Deduction For Child Support Payments , Reginald Mombrun

Fordham Journal of Corporate & Financial Law

No abstract provided.


The Irs’S Cost-Sharing Proposals In The Worldwide Tax System: Why Congress Should Avoid Anti-Competitive Transfer Pricing Regulations And Embrace A Territorial Tax, James D. Mandolfo Jan 2007

The Irs’S Cost-Sharing Proposals In The Worldwide Tax System: Why Congress Should Avoid Anti-Competitive Transfer Pricing Regulations And Embrace A Territorial Tax, James D. Mandolfo

Fordham Journal of Corporate & Financial Law

No abstract provided.


New York Revises Ethics Rules To Permit Limited Mdps: A Critical Analysis Of The New York Approach, The Future Of The Mdp Debate After Enron, And Recommendations For Other Jurisdictions, John P. Lucci Jan 2003

New York Revises Ethics Rules To Permit Limited Mdps: A Critical Analysis Of The New York Approach, The Future Of The Mdp Debate After Enron, And Recommendations For Other Jurisdictions, John P. Lucci

Fordham Journal of Corporate & Financial Law

No abstract provided.