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Articles 1 - 10 of 10
Full-Text Articles in Law
U.S. Taxation Of Profits From Internet Software Sales - An Electronic Commerce Case Study, J. Clifton Fleming Jr.
U.S. Taxation Of Profits From Internet Software Sales - An Electronic Commerce Case Study, J. Clifton Fleming Jr.
Faculty Scholarship
No abstract provided.
Getting Serious About Curtailing Deferral Of Us Tax On Foreign Source Income, Robert J. Peroni, J. Clifton Fleming Jr., Stephen E. Shay
Getting Serious About Curtailing Deferral Of Us Tax On Foreign Source Income, Robert J. Peroni, J. Clifton Fleming Jr., Stephen E. Shay
Faculty Scholarship
When a U.S. person conducts business or investment activity abroad through a foreign corporation in a country that imposes only low rates of tax, the so-called deferral privilege allows the U.S. taxpayer to defer substantial amounts of U.S. tax at the cost of only a small foreign levy. Hence, the deferral privilege operates as a tax subsidy of sorts for U.S. persons with operations in low tax foreign countries and provides a major incentive for U.S. persons to shift their business operations and investments to foreign countries that impose little or no tax on the earnings of the foreign corporations.To …
Recent Federal Income Tax Developments, Ira B. Shepard
Recent Federal Income Tax Developments, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Tax Lawyers, Ethical Obligations, And The Duty To The System, Watson
Tax Lawyers, Ethical Obligations, And The Duty To The System, Watson
Scholarly Works
Perhaps the most elusive area of law is that of legal ethics. While the term itself is easy to define,' the subject all but defies codification because ethics, or morals (the terms are interchangeable), cannot be encapsulated by or in law. This is because law, in general, contains its own standard of validity on which there is usually clear societal consensus. For example, murder, rape, and theft are morally repugnant universally. Hence, punishment for any of these offenses does not impinge upon religious or individual autonomy because there is no ethical freedom to choose whether or not to engage in …
The Roth Ira Cuts Federal Revenues, With No Benefit To Taxpayers, Michael Waggoner
The Roth Ira Cuts Federal Revenues, With No Benefit To Taxpayers, Michael Waggoner
Publications
No abstract provided.
"To Lay And Collect Taxes": The Constitutional Case For Progressive Taxation, Leo P. Martinez
"To Lay And Collect Taxes": The Constitutional Case For Progressive Taxation, Leo P. Martinez
Faculty Scholarship
No abstract provided.
International Comity And The Foreign Tax Credit: Crediting Nonconforming Taxes, Glenn E. Coven
International Comity And The Foreign Tax Credit: Crediting Nonconforming Taxes, Glenn E. Coven
Faculty Publications
No abstract provided.
The Dangers Of Symbolic Legislation: Perceptions And Realities Of The New Burden-Of-Proof Rules, Steve R. Johnson
The Dangers Of Symbolic Legislation: Perceptions And Realities Of The New Burden-Of-Proof Rules, Steve R. Johnson
Articles by Maurer Faculty
One provision of the 1998 IRS Restructuring and Reform Act is new I.R.C. sec. 7491. That section purports to alter the long established rule that the burden of proof in civil tax litigation generally is on the taxpayer. It was enacted with considerable fanfare as a taxpayer-protection measure. However, to minimize the serious effects that a genuine and general burden reversal would occasion, sec. 7491 contains many exceptions and limitations. I argue that these conditions largely swallow the rule, such that the burden of proof will shift in very few actual cases. But ineffective does not mean innocuous. Section 7491 …
Caring Enough: Sex Roles, Work And Taxing Women, Amy L. Wax
Caring Enough: Sex Roles, Work And Taxing Women, Amy L. Wax
All Faculty Scholarship
No abstract provided.
Tax Consequences Of Assigning Life Insurance - Time For Another Look, Douglas A. Kahn, Lawrence W. Waggoner
Tax Consequences Of Assigning Life Insurance - Time For Another Look, Douglas A. Kahn, Lawrence W. Waggoner
Articles
The Taxpayer Relief Act of 1997 furnishes the courts and the Internal Revenue Service an opportunity to close certain loopholes in the federal tax consequences of assigning life insurance. About twenty years ago, we published an article arguing that the tax consequences of assigning life insurance affords taxpayers unwarranted opportunities for tax avoidance. Since then, developments in the case law and Internal Revenue Service rulings have broadened the loopholes. In the update of our article, we show how the new tax law supports our original position.