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Articles 1 - 30 of 49
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 …
The "Original Intent" Of The Federal Tax Treatment Of Private Pension Plans, James A. Wooten
The "Original Intent" Of The Federal Tax Treatment Of Private Pension Plans, James A. Wooten
Other Scholarship
No abstract provided.
Capitalization In The Nineties, Glenn R. Carrington
Capitalization In The Nineties, Glenn R. Carrington
William & Mary Annual Tax Conference
No abstract provided.
Selected Current Developments In Financial Accounting And Reporting, David W. Larue
Selected Current Developments In Financial Accounting And Reporting, David W. Larue
William & Mary Annual Tax Conference
No abstract provided.
Taxable And Tax-Free Acquisitions And Separations, Mark J. Silverman, Robert H. Wellen, Mark L. Yecies
Taxable And Tax-Free Acquisitions And Separations, Mark J. Silverman, Robert H. Wellen, Mark L. Yecies
William & Mary Annual Tax Conference
No abstract provided.
Contingent Consideration And Contingent Liabilities In Acquisitions: Outline,Addendum, References, Robert H. Wellen
Contingent Consideration And Contingent Liabilities In Acquisitions: Outline,Addendum, References, Robert H. Wellen
William & Mary Annual Tax Conference
No abstract provided.
Section 338(H)(10), Mark L. Yecies
Section 338(H)(10), Mark L. Yecies
William & Mary Annual Tax Conference
No abstract provided.
Corporate Divisions Under Section 355, Mark J. Silverman
Corporate Divisions Under Section 355, Mark J. Silverman
William & Mary Annual Tax Conference
No abstract provided.
Federal And State Audit Issues, William L.S. Rowe, D. French Slaughter Iii
Federal And State Audit Issues, William L.S. Rowe, D. French Slaughter Iii
William & Mary Annual Tax Conference
No abstract provided.
Use Of Limited Liability Companies In Corporate Transactions, Mark J. Silverman, Lisa M. Zarlenga
Use Of Limited Liability Companies In Corporate Transactions, Mark J. Silverman, Lisa M. Zarlenga
William & Mary Annual Tax Conference
No abstract provided.
Section 338(H)(10) & Appendix, Mark J. Silverman, Jonathan I. Forrest
Section 338(H)(10) & Appendix, Mark J. Silverman, Jonathan I. Forrest
William & Mary Annual Tax Conference
No abstract provided.
The Influence Of Income Tax Rules On Insurance Reserves, David F. Bradford, Kyle D. Logue
The Influence Of Income Tax Rules On Insurance Reserves, David F. Bradford, Kyle D. Logue
Book Chapters
An insurance company is a financial intermediary whose main line of business is the sale of a particular type of contingent contract, called an insurance policy. Under this contract, the insurer promises to pay some amount to the policyholder, or to some other beneficiary, following the occurrence of an insured event. In the context of property-casualty insurance, the relevant insured events include, for example, the accidental destruction of the insured's property or the award of a liability judgment against the insured. In return for this promise the insured pays the insurer a premium. The premium and the earnings on the …
And The 1999 Award For The Worst Opinion In A Tax Case Goes To -, Deborah A. Geier
And The 1999 Award For The Worst Opinion In A Tax Case Goes To -, Deborah A. Geier
Law Faculty Articles and Essays
This article critiques the opinion in Owen v. United States by Judge Jerome Turner of the Western District of Tennessee.
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 …
Ten Limitations To Ponder On Farm Limited Liability Companies, Jesse Richardson, L. Leon Geyer
Ten Limitations To Ponder On Farm Limited Liability Companies, Jesse Richardson, L. Leon Geyer
Law Faculty Scholarship
No abstract provided.
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance? (Symposium), Evelyn Brody
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance? (Symposium), Evelyn Brody
All Faculty Scholarship
No abstract provided.
Charities In Tax Reform: Threats To Subsidies Overt And Covert, Evelyn Brody
Charities In Tax Reform: Threats To Subsidies Overt And Covert, Evelyn Brody
All Faculty Scholarship
Fundamental tax reform would do far more damage to charities than the obvious repeal of the deduction for charitable contributions. Over the decades, charities have quietly garnered billions of dollars worth of indirect benefits. For example, the largest tax expenditure - the exclusion from workers' income of employer-provided health insurance - has fattened nonprofit hospitals, and the new tuition tax credits promise to spur tuition inflation. Tax reform presents an opportunity to eliminate tax subsidies and enact any desired direct expenditures for specific public goods and activities. However, converting tax expenditures to direct outlays would likely take the form of …
State Comparative Chart Llc And Llp Statutes, James J. Wheaton
State Comparative Chart Llc And Llp Statutes, James J. Wheaton
William & Mary Annual Tax Conference
No abstract provided.
Square Pegs In Round Holes: Llcs Under Other Statutes, James J. Wheaton
Square Pegs In Round Holes: Llcs Under Other Statutes, James J. Wheaton
William & Mary Annual Tax Conference
No abstract provided.
Observing Money, Marriage And Taxation, Ann F. Thomas
Observing Money, Marriage And Taxation, Ann F. Thomas
Articles & Chapters
No abstract provided.
Child Care And Federal Tax Policy, Ann F. Thomas
Child Care And Federal Tax Policy, Ann F. Thomas
Articles & Chapters
No abstract provided.
Implications Of The Tax Reform Proposals For Fraud – Or – How To Shift To A Consumption Tax Without Helping The Cheaters, Kalyani Robbins
Implications Of The Tax Reform Proposals For Fraud – Or – How To Shift To A Consumption Tax Without Helping The Cheaters, Kalyani Robbins
Faculty Publications
The vast majority of the proposals on the table today are simply different implementation mechanisms of the same basic idea: a change in the tax base from income to consumption. The purpose of this article is to consider the implications some of these proposals have for the enforcement of tax compliance (prevention of cheating). For this reason, it will only briefly address the impetus for a consumption tax and the policy considerations behind it. The first part will also give short descriptions of the proposals that will be considered in this article: the National Retail Sales Tax, the Savings-Exempt Income …
Foreword, “Symposium 1999: Women, Equity And Federal Tax Policy: Open Questions.” ., Ann F. Thomas
Foreword, “Symposium 1999: Women, Equity And Federal Tax Policy: Open Questions.” ., Ann F. Thomas
Articles & Chapters
No abstract provided.
Marriage And The Income Tax Yesterday, Today, And Tomorrow: A Primer And Legislative Scorecard, Ann F. Thomas
Marriage And The Income Tax Yesterday, Today, And Tomorrow: A Primer And Legislative Scorecard, Ann F. Thomas
Articles & Chapters
No abstract provided.
Child Care And Federal Tax Policy (Symposium: Women, Equity And Federal Tax Policy: Open Questions), Ann F. Thomas
Child Care And Federal Tax Policy (Symposium: Women, Equity And Federal Tax Policy: Open Questions), Ann F. Thomas
Articles & Chapters
No abstract provided.
Transfer Pricing, Anders Leif Allvin
Transfer Pricing, Anders Leif Allvin
LLM Theses and Essays
Transfer pricing is one of the principal international taxation issues of the 1990s and potentially of future decades as well. For corporate enterprises, it can be difficult enough to do business in just one country, but it gets even more complex when they go international. The growth of multinational enterprises (MNEs) creates complex taxation issues for both the tax administrations as well for the MNE. Transfer pricing concerns allocation of income earned within affiliated corporate groups in different countries, which must satisfy tax authorities that they are not evading taxes through the use of transfer pricing. The main problem with …
Implications Of The Tax Reform Proposals For Fraud – Or – How To Shift To A Consumption Tax Without Helping The Cheaters, Kalyani Robbins
Implications Of The Tax Reform Proposals For Fraud – Or – How To Shift To A Consumption Tax Without Helping The Cheaters, Kalyani Robbins
Akron Law Faculty Publications
The vast majority of the proposals on the table today are simply different implementation mechanisms of the same basic idea: a change in the tax base from income to consumption. The purpose of this article is to consider the implications some of these proposals have for the enforcement of tax compliance (prevention of cheating). For this reason, it will only briefly address the impetus for a consumption tax and the policy considerations behind it. The first part will also give short descriptions of the proposals that will be considered in this article: the National Retail Sales Tax, the Savings-Exempt Income …
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.
A Proposal For Integrating The Income And Transfer Taxation Of Trusts, Robert T. Danforth
A Proposal For Integrating The Income And Transfer Taxation Of Trusts, Robert T. Danforth
Scholarly Articles
Present law fails to integrate the income and transfer (i.e., estate and gift) taxation of trusts; a gratuitous transfer to a trust may be incomplete for income tax purposes (producing a so-called grantor trust, the income of which is taxed to the grantor), but complete for transfer tax purposes. Grantors create trusts that exploit two features of this tax law dichotomy: the grantor's income tax payments on trust income enhance the value of the trust by allowing it to appreciate in value income tax free; and present law provides no basis for subjecting this enhanced value to gift or estate …