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Articles 1 - 30 of 50
Full-Text Articles in Law
Scoping Out The Uncertain Simplification (Complication?) Effects Of Vats, Bats, And Consumed Income Taxes, J. Clifton Fleming Jr.
Scoping Out The Uncertain Simplification (Complication?) Effects Of Vats, Bats, And Consumed Income Taxes, J. Clifton Fleming Jr.
Faculty Scholarship
No abstract provided.
Ethical Issues In Tax Practice, Robert I. Brauer, James P. Holden
Ethical Issues In Tax Practice, Robert I. Brauer, James P. Holden
William & Mary Annual Tax Conference
No abstract provided.
Office Of Director Of Practice, Robert I. Brauer
Office Of Director Of Practice, Robert I. Brauer
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entity - Tax Issues, Lisa M. Landry
Choice Of Entity - Tax Issues, Lisa M. Landry
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entity - General Considerations, L. Michael Gracik Jr.
Choice Of Entity - General Considerations, L. Michael Gracik Jr.
William & Mary Annual Tax Conference
No abstract provided.
Case Studies: Small Professional Services Organization And Large Professional Services Organization, L. Michael Gracik Jr.
Case Studies: Small Professional Services Organization And Large Professional Services Organization, L. Michael Gracik Jr.
William & Mary Annual Tax Conference
No abstract provided.
Choice Of Entity - Flexibility, Exit Strategy, Thomas R. Frantz
Choice Of Entity - Flexibility, Exit Strategy, Thomas R. Frantz
William & Mary Annual Tax Conference
No abstract provided.
Hypotheticals: Numbers 1 & 2, Lisa M. Landry
Hypotheticals: Numbers 1 & 2, Lisa M. Landry
William & Mary Annual Tax Conference
No abstract provided.
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Allocation Of Nonrecourse Liabilities: Irs Takes Two Steps Forward, One Back, J. D. Dell, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
Planning Opportunities Remain Under The Final Partnership Allocation Rules For Contributed Property, Michael G. Frankel, Leslie H. Loffman, Sanford C. Presant
William & Mary Annual Tax Conference
No abstract provided.
Tax Considerations In The Formation And Operation Of Limited Liability Companies, Blake D. Rubin, Howard T. Widra
Tax Considerations In The Formation And Operation Of Limited Liability Companies, Blake D. Rubin, Howard T. Widra
William & Mary Annual Tax Conference
No abstract provided.
Meeting With Irs Regarding Partnership Issues In Developing Section 1017 Regulations, Blake D. Rubin
Meeting With Irs Regarding Partnership Issues In Developing Section 1017 Regulations, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
Partnership Workouts: Problems And Solutions Under Final Section 704(B) And 752 Regulations, Michael G. Frankel, Charles H. Coffin
William & Mary Annual Tax Conference
No abstract provided.
Case Studies: Scenarios Nos. 1, 2 & 3, Thomas R. Frantz
Case Studies: Scenarios Nos. 1, 2 & 3, Thomas R. Frantz
William & Mary Annual Tax Conference
No abstract provided.
Focus On Capitalization V. Deductibility - Environmental Remediation, Stefan F. Tucker
Focus On Capitalization V. Deductibility - Environmental Remediation, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
The Tax Treatment Of Environmental Cleanup Costs, Blake D. Rubin, Seth Green, Katherine P. Rosefsky
The Tax Treatment Of Environmental Cleanup Costs, Blake D. Rubin, Seth Green, Katherine P. Rosefsky
William & Mary Annual Tax Conference
No abstract provided.
Principal Differences In Application Of Classification Rules To Limited Liability Companies Compared To Limited Partnerships, Blake D. Rubin
Principal Differences In Application Of Classification Rules To Limited Liability Companies Compared To Limited Partnerships, Blake D. Rubin
William & Mary Annual Tax Conference
No abstract provided.
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.
Creative Financing, Stefan F. Tucker
Creative Financing, Stefan F. Tucker
William & Mary Annual Tax Conference
No abstract provided.
Tax Considerations In The Formation And Operation Of Limited Liability Companies, Blake D. Rubin, Howard T. Widra
Tax Considerations In The Formation And Operation Of Limited Liability Companies, Blake D. Rubin, Howard T. Widra
William & Mary Annual Tax Conference
No abstract provided.
Bringing Small Business Development To Urban Neighborhoods, Robert E. Suggs
Bringing Small Business Development To Urban Neighborhoods, Robert E. Suggs
Faculty Scholarship
This article describes a race-neutral policy proposal designed to increase business formation and success rates for young urban African Americans. The proposal suggests using local governments' taxing authority, in a manner analogous to tax increment financing, to create financial incentives for successful small business owners to employ, and then mentor and train as business owners, young urban entrepreneurs from deteriorating neighborhoods. The amount of financial incentive varies directly with financial success of protégés and requires the transfer of some of the mentor’s social (reputational) capital to the protégé. Business activity has created wealth and economic mobility for other ethnic groups, …
The International Implications Of Tax Reform, Reuven Avi-Yonah
The International Implications Of Tax Reform, Reuven Avi-Yonah
Articles
This article examines the U.S. tax consequences of the use of derivative instruments in international financing transactions. The outline focuses in large part on the inconsistent U.S. tax treatment that results &om the use of various derivative financial instruments in cross-border financing transactions and the resulting implications for U.S. withholding taxes on ordinary equity and debt investments.
Simon Says: A Liddle Night Music With Those Depreciation Deductions, Please, Deborah A. Geier, Joseph M. Dodge
Simon Says: A Liddle Night Music With Those Depreciation Deductions, Please, Deborah A. Geier, Joseph M. Dodge
Law Faculty Articles and Essays
This 1995 article, co-authored with Joseph M. Dodge, explores why the decision in Simon v. Commissioner, 103 T.C. 247 (1994), was wrong, effectively allowing premature deduction of a capital expenditure and, thus, consumption taxation (as opposed to income taxation).
The Death (And Taxes) Of A Partner, Stephen Utz
The Death (And Taxes) Of A Partner, Stephen Utz
Faculty Articles and Papers
No abstract provided.
Fog, Fairness, And The Federal Fisc: Tenancy-By-The-Entireties And The Federal Tax Lien, Steve R. Johnson
Fog, Fairness, And The Federal Fisc: Tenancy-By-The-Entireties And The Federal Tax Lien, Steve R. Johnson
Scholarly Publications
No abstract provided.
Commerce Clause Restraints On State Taxation After Jefferson Lines, Walter Hellerstein, Michael J. Mcintyre, Richard D. Pomp
Commerce Clause Restraints On State Taxation After Jefferson Lines, Walter Hellerstein, Michael J. Mcintyre, Richard D. Pomp
Scholarly Works
The Supreme Court's 1977 decision in Complete Auto Transit, Inc. v. Brady signaled a paradigmatic shift in the Court's approach to state tax adjudication under the dormant Commerce Clause. In Complete Auto, the Court repudiated the formalistic school of interpretation that once had governed Commerce Clause analysis of state taxation because it bore ‘no relationship to economic realities.’ In its place, the Court embraced a decisional framework that ‘considered not the formal language of the tax statute but rather its practical effect.’ In furtherance of this objective, the Court suggested a four-part test to guide the constitutional analysis of state …
The Tax Treatment Of Limited Liability Companies: Law In Search Of Policy, Daniel S. Goldberg
The Tax Treatment Of Limited Liability Companies: Law In Search Of Policy, Daniel S. Goldberg
Faculty Scholarship
No abstract provided.
The Lingering Demise Of Tax Exempt Mutual And Captive Insurance Companies, Darryll K. Jones
The Lingering Demise Of Tax Exempt Mutual And Captive Insurance Companies, Darryll K. Jones
Journal Publications
Prior to the enactment of IRC §501(m), the issue of whether a group self-insurance pool was tax exempt generally depended upon an analysis of the "substantial purpose" requirement contained in Treasury Regulation §1.501(c)(3)-1(c)(1) which denies tax exempt status to an entity or organization if "more than an insubstantial part of its activities is not in furtherance of an exempt purpose." In addition, Treas. Reg. §1.501(c)(3)-1(e)(1) allows an entity to operate a trade or business as a substantial part of its activities but only "if the operation of such trade or business is in furtherance of the organization's exempt purpose.... Thus, …
Limited Liability Partnerships, James J. Wheaton
Limited Liability Partnerships, James J. Wheaton
William & Mary Annual Tax Conference
No abstract provided.
Case Studies: Operating Business And Venture Business, James J. Wheaton
Case Studies: Operating Business And Venture Business, James J. Wheaton
William & Mary Annual Tax Conference
No abstract provided.