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Articles 1 - 11 of 11
Full-Text Articles in Law
The Missing U.S. Vat: Economic Inequality, American Fiscal Exceptionalism, And The Historical U.S. Resistance To National Consumption Taxes, Ajay K. Mehrotra
The Missing U.S. Vat: Economic Inequality, American Fiscal Exceptionalism, And The Historical U.S. Resistance To National Consumption Taxes, Ajay K. Mehrotra
Northwestern University Law Review
Since the 1970s, economic inequality has soared dramatically across the globe and particularly in the United States. In that time, one of the obstacles of using fiscal policy to address inequality has been the growing myth of the “overtaxed American”—the misguided notion that U.S. taxpayers pay more in taxes than residents of other advanced, industrialized countries. This myth has persisted, in part, because of the peculiar and distinctive nature of the fractured American fiscal and social welfare state. Even a cursory review of comparative tax data shows that the United States, by most measures, is a low-tax country compared to …
Nobody’S Stock Compares To Your Own: How Treasury Can Revive Stock Compensation In Cost-Sharing Agreements, Tyler Johnson
Nobody’S Stock Compares To Your Own: How Treasury Can Revive Stock Compensation In Cost-Sharing Agreements, Tyler Johnson
Northwestern University Law Review
In Altera Corp. v. Commissioner, the United States Tax Court invalidated a 2003 Treasury Regulation for failing to meet State Farm’s reasoned decisionmaking standard under the Administrative Procedure Act (APA). Invalidating this specific regulation eliminates one of the federal government’s latest attempts to limit income tax avoidance by some of the world’s largest and wealthiest corporations in the murky world of transfer pricing. This Note demonstrates that the Tax Court’s ruling must be limited to its specific APA holding and argues that Treasury may enact a similar regulation under the existing statutory and regulatory framework of the arm’s length …
Tax Cannibalization And Fiscal Federalism In The United States, David Gamage, Darien Shanske
Tax Cannibalization And Fiscal Federalism In The United States, David Gamage, Darien Shanske
Northwestern University Law Review
We began this project pondering a riddle. Most state governments have adopted what we—and many others—view as clearly suboptimal tax policies, especially in regard to the taxation of corporate income and capital gains. Yet, with the notable exception of those who oppose progressivity and the taxation of capital, state-level tax policymakers have had remarkably little appetite for reform. This Article provides one major explanation for this riddle by identifying and demonstrating a phenomenon that we label as “tax cannibalization.” We argue that flawed state-level tax policies derive in part from perverse incentives inadvertently created by the federal government.
Finding The Pearl In The Oyster: Supercharging Ipos Through Tax Receivable Agreements, Christopher B. Grady
Finding The Pearl In The Oyster: Supercharging Ipos Through Tax Receivable Agreements, Christopher B. Grady
Northwestern University Law Review
A new, “supercharged” form of IPO has slowly developed over the last twenty years. This new form of IPO takes advantage of several seemingly unrelated provisions of the tax code to multiply pre-IPO owners’ proceeds from a public offering without reducing the amount public investors are willing to pay for the stock. Supercharged IPOs use a tax receivable agreement to transfer tax assets created by the IPO back to the pre-IPO ownership, “monetizing” the tax assets. As these structures have become more efficient, commentators have expressed concerns that these agreements deceive shareholders who either ignore or do not understand the …
The Moonscape Of Tax Equality: Windsor And Beyond, Anthony C. Infanti
The Moonscape Of Tax Equality: Windsor And Beyond, Anthony C. Infanti
Northwestern University Law Review
No abstract provided.
Tax-Free Reorganizations: The Evolution And Revolution Of Triangular Mergers, Stephanie Hoffer, Dale A. Oesterle
Tax-Free Reorganizations: The Evolution And Revolution Of Triangular Mergers, Stephanie Hoffer, Dale A. Oesterle
Northwestern University Law Review
No abstract provided.
A Corporate Tax For The Next One Hundred Years: A Proposal For A Dynamic, Self-Adjusting Corporate Tax Rate, Adam H. Rosenzweig
A Corporate Tax For The Next One Hundred Years: A Proposal For A Dynamic, Self-Adjusting Corporate Tax Rate, Adam H. Rosenzweig
Northwestern University Law Review
No abstract provided.
Does Federal Spending "Coerce" States? Evidence From State Budgets, Brian Galle
Does Federal Spending "Coerce" States? Evidence From State Budgets, Brian Galle
Northwestern University Law Review
No abstract provided.
A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie Hunter Mcmahon
A Bundle Of Confusion For The Income Tax: What It Means To Own Something, Stephanie Hunter Mcmahon
Northwestern University Law Review
No abstract provided.
Schedularity In U.S. Income Taxation And Its Effect On Tax Distribution, Henry Ordower
Schedularity In U.S. Income Taxation And Its Effect On Tax Distribution, Henry Ordower
Northwestern University Law Review
No abstract provided.
What A History Of Tax Withholding Tells Us About The Relationship Between Statutes And Constitutional Law, Anuj C. Desai
What A History Of Tax Withholding Tells Us About The Relationship Between Statutes And Constitutional Law, Anuj C. Desai
Northwestern University Law Review
No abstract provided.