Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Taxation (4)
- AMT reform (1)
- Alternative minimum tax (1)
- Automatic stabilization (1)
- Business entities (1)
-
- Capital import neutrality (CIN) (1)
- Capital export neutrality (CEN) (1)
- Capital ownership neutrality (CON) (1)
- Charles Rangel (1)
- Chicago Tribune Company (1)
- Closely held businesses (1)
- Corporate tax (1)
- Definition of family (1)
- Direct investment (1)
- ESOP (1)
- Economics (1)
- Employee Stock Ownership Plan (1)
- Estate and gift tax (1)
- Estate tax (1)
- Family LLC (1)
- Federal remedies (1)
- Feminism (1)
- Foreign investment (1)
- Gender Studies (1)
- Government (1)
- H.R. 4137 (1)
- Immigration Law (1)
- Income Taxation (1)
- Income tax (1)
- Indirect claims on equity (1)
Articles 1 - 9 of 9
Full-Text Articles in Law
Linton Family Llc And The Step Transaction Doctrine, Wendy G. Gerzog
Linton Family Llc And The Step Transaction Doctrine, Wendy G. Gerzog
All Faculty Scholarship
This article discusses Linton, a district court decision about a family limited liability company, indirect gifts, and the step transaction doctrine.
State Finance In Times Of Crisis, Brian Galle, Jonathan Klick
State Finance In Times Of Crisis, Brian Galle, Jonathan Klick
All Faculty Scholarship
As recent events illustrate, state finances are pro-cyclical: during recessions, state revenues crash, worsening the effects of economic downturns. This problem is well-known, yet persistent. We argue here that, in light of predictable federalism and political economy dynamics, states will be unable to change this situation on their own. Additionally, we note that many possible federal remedies may result in worse problems, such as creating moral hazard that would induce states to take on excessively risky policy, both fiscal and otherwise. Thus, we argue that policy makers should consider so-called “automatic” stabilizers, such as are found in the federal tax …
Families For Tax Purposes: What About The Steps, Wendy G. Gerzog
Families For Tax Purposes: What About The Steps, Wendy G. Gerzog
All Faculty Scholarship
At least 4.4 million families in the U.S. are blended ones that include step-children and step-parents. For tax purposes, these steps receive preferential treatment for their status because they are on the one hand included as family members for many income tax benefit sections, but on the other hand excluded as family members for business entity attribution purposes and for gift and estate tax anti-abuse provisions. In the interests of fairness and uniformity, steps should be treated as family members for all tax purposes where steps have in fact voluntarily acted as their biological or adoptive counterparts, both when such …
Negron: Circuits Now Split 2-2, Wendy G. Gerzog
Negron: Circuits Now Split 2-2, Wendy G. Gerzog
All Faculty Scholarship
The article discusses Negron and the circuit split on the issue of whether to value non-assignable lottery payments in a decedent's estate by means of the actuarial tables or whether that value needs to be discounted for non-marketability.
Integrating Subchapters K And S — Just Do It, Walter D. Schwidetzky
Integrating Subchapters K And S — Just Do It, Walter D. Schwidetzky
All Faculty Scholarship
The Code contains two “pass-through” tax regimes for business entities. One is contained in Subchapter K, which applies to partnerships, the other in Subchapter S, which, unsurprisingly, applies to S corporations. In the main, both Subchapters tax the owners of the entities rather than the entities themselves. Having two pass-through tax regimes creates obvious administrative and other inefficiencies. There was a time when S corporations served a valuable purpose, particularly when taxpayers needed a fairly simple and foolproof pass-through entity that provided a liability shield. But limited liability companies (LLCs), which are usually taxed as partnerships, 1 in most contexts …
Taxation And The Competitiveness Of Sovereign Wealth Funds: Do Taxes Encourage Sovereign Wealth Funds To Invest In The United States?, Michael S. Knoll
Taxation And The Competitiveness Of Sovereign Wealth Funds: Do Taxes Encourage Sovereign Wealth Funds To Invest In The United States?, Michael S. Knoll
All Faculty Scholarship
Sovereign wealth funds (SWFs) control vast amounts of capital and have made and are continuing to make numerous large, high-profile investments in the United States, especially in the financial services industry. Those investments in particular and SWFs in general are highly controversial. There is much discussion of the advantages and disadvantages to the United States of investments by SWFs and there is an intense and ongoing debate over what should be the United States’ policy towards investments by SWFs. In the course of that debate, some critics have called upon the US government to abandon its long-held public position of …
Immigration Restriction As Redistributive Taxation: Working Women And The Costs Of Protectionism In The Labor Market, Howard F. Chang
Immigration Restriction As Redistributive Taxation: Working Women And The Costs Of Protectionism In The Labor Market, Howard F. Chang
All Faculty Scholarship
In this paper, I argue that tax and transfer policies are more efficient than immigration restrictions as instruments for raising the after-tax incomes of the least skilled native workers. Policies to protect these native workers from immigrant competition in the labor market do no better at promoting distributive justice and are likely to impose a greater economic burden on natives in the country of immigration than the tax alternative. These immigration restrictions are especially costly given the disproportionate burden that they place on households with working women, which discourages female participation in the labor force. This burden runs contrary to …
Samuel Zell, The Chicago Tribune, And The Emergence Of The S Esop: Understanding The Tax Advantages And Disadvantages Of S Esops, Michael S. Knoll
Samuel Zell, The Chicago Tribune, And The Emergence Of The S Esop: Understanding The Tax Advantages And Disadvantages Of S Esops, Michael S. Knoll
All Faculty Scholarship
Samuel Zell’s acquisition of the Chicago Tribune Company (the Tribune) in December 2007 using a little-known type of Employee Stock Ownership Plan (ESOP) made headlines. In a complicated transaction, which took nearly a year to complete, the Tribune converted from a subchapter C corporation to a subchapter S corporation, established an ESOP that purchased 100 percent of the company’s equity, and sold Zell a call option giving him the right to purchase 40 percent of the company’s equity. Press reports claim that Zell’s novel structure enabled Zell to outbid other suitors. And financial commentators predict that many acquirers will employ …
Return Of The Poll Tax: How The Internet Threatens 200 Years Of Progress Toward Equality, Max Oppenheimer
Return Of The Poll Tax: How The Internet Threatens 200 Years Of Progress Toward Equality, Max Oppenheimer
All Faculty Scholarship
No abstract provided.