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Articles 1 - 11 of 11
Full-Text Articles in Law
Who's At Risk? Abbott And Costello Take On Section 465, Ajay Gupta
Who's At Risk? Abbott And Costello Take On Section 465, Ajay Gupta
University of Miami Business Law Review
No abstract provided.
The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll
The Taxation Of Private Equity Carried Interests: Estimating The Revenue Effects Of Taxing Profit Interests As Ordinary Income, Michael S. Knoll
William & Mary Law Review
In this Article, I estimate the tax revenue effects of taxing private equity carried interests as ordinary income rather than as long-term capital gain as under current law. Under reasonable assumptions, I conclude that the expected present value of additional tax collections would be between 1 percent and 1.5 percent of capital invested in private equity funds, or between $2 billion and $3 billion a year. That estimate, however, makes no allowance for changes in the structure of such funds or the composition of the partnerships, which might substantially reduce tax revenues below those estimates.
Going From The Frying Pan Into The Fire? A Critique Of The U.S. Treasury's Newly Proposed Section 987 Currency Regulations, Joseph Tobin
Going From The Frying Pan Into The Fire? A Critique Of The U.S. Treasury's Newly Proposed Section 987 Currency Regulations, Joseph Tobin
University of Miami Business Law Review
No abstract provided.
Federal Tax Consequences Of Virtual World Transactions, G. Martin Bingisser
Federal Tax Consequences Of Virtual World Transactions, G. Martin Bingisser
Washington Journal of Law, Technology & Arts
This article discusses the tax consequences of transactions involving Massive Multiplayer Online Role Playing Games (“MMORPGs”). MMORPGs have recently grown in popularity and developed significant economic activity. Virtual goods used in these games are traded for both real and virtual currency. While few dispute that a sale of virtual goods for real currency is a taxable event, more complex tax issues arise concerning transactions that occur solely within virtual worlds. This article analyzes the tax consequences and policy issues surrounding such transactions.
The Unintended Tax Advantages Of Gay Marriage, Theodore P. Seto
The Unintended Tax Advantages Of Gay Marriage, Theodore P. Seto
Washington and Lee Law Review
The Internal Revenue Code (the Code) contains numerous special rules applicable to the income taxation of persons related by marriage, birth, adoption, or ownership. This Article suggests a new approach to their analysis. Many basic tax rules assume that taxpayers are self-interested and unaffiliated. Where this assumption is incorrect, the Code makes adjustments to its otherwise applicable rules. Most of the resulting related-party antiavoidance rules apply only in the context of specified formal relationships-marriage, parent/child, or owner/business. The Article tests this thesis by comparing the income tax treatment of heterosexual married couples with that of gay couples in committed long-term …
Federal Taxation, Michael H. Plowgian, Svetoslav S. Minkov, Mark S. Davis
Federal Taxation, Michael H. Plowgian, Svetoslav S. Minkov, Mark S. Davis
Mercer Law Review
The courts in the Eleventh Circuit heard a number of relatively prominent tax related cases in 2007. In United States v. Mount Sinai Medical Center of Florida, Inc., the Eleventh Circuit held that medical residents are potentially eligible for the student exemption from social security taxes, with their eligibility being determined on a case-by-case basis. In Estate of Jelke v. Commissioner, the Eleventh Circuit vacated the United States Tax Court's valuation methodology in computing, for estate tax purposes, the net asset value of a holding company in which the decedent held a minority interest. The Eleventh Circuit held …
Corporate Taxation And International Charter Competition, Mitchell A. Kane, Edward B. Rock
Corporate Taxation And International Charter Competition, Mitchell A. Kane, Edward B. Rock
Michigan Law Review
Corporate charter competition has become an increasingly international phenomenon. The thesis of this Article is that this development in corporate law requires a greater focus on corporate tax law. We first demonstrate how a tax system's capacity to distort the international charter market depends both upon its approach to determining corporate location and upon the extent to which it taxes foreign source corporate profits. We also show, however, that it is not possible to remove all distortions through modifications to the tax system alone. We present instead two alternative methods for preserving an international charter market. The first-best solution involves …
Democracy And Opportunity: A New Paradigm In Tax Equity, James R. Repetti
Democracy And Opportunity: A New Paradigm In Tax Equity, James R. Repetti
Vanderbilt Law Review
Academics and policymakers pay little attention to the interaction of a tax system with the objectives of a just government. For example, in the debate about whether the United States should retain an income tax or adopt a consumption tax, most discussions focus on the relative efficiency and equity of the taxes. Proponents of a consumption tax worry that an income tax is inefficient because it burdens investment income. Advocates of an income tax fear that a consumption tax is not equitable because low-income taxpayers consume a greater percentage of their income than wealthy taxpayers. These concerns date at least …
Federal Fairness To State Taxpayers: Irrationality, Unfunded Mandates, And The "Salt" Deduction, Brian Galle
Federal Fairness To State Taxpayers: Irrationality, Unfunded Mandates, And The "Salt" Deduction, Brian Galle
Michigan Law Review
By sheer dollars alone, the largest impact of the Alternative Minimum Tax is to deny many taxpayers the deduction for the taxes they paid to their state and local governments under § 164 of the Internal Revenue Code. This Article provides a fine-grained analysis of the overall fairness of the state-andlocal- tax deduction--and, by implication, the fairness of its partial repeal through the Alternative Minimum Tax. I offer for the first time a close examination of how newly understood limits on taxpayer mobility and rationality might affect individuals' choices of bundles of local taxes and localgovernment services, which in turn …
Advocacy Groups Plead With Congress To Reauthorize The Secure Rural Schools And Community Self-Determination Act, Nigel D. Graham
Advocacy Groups Plead With Congress To Reauthorize The Secure Rural Schools And Community Self-Determination Act, Nigel D. Graham
Public Interest Law Reporter
No abstract provided.
A Coherent Policy Proposal For U.S. Residence-Based Taxation Of Individuals, Cynthia Blum, Paula N. Singer
A Coherent Policy Proposal For U.S. Residence-Based Taxation Of Individuals, Cynthia Blum, Paula N. Singer
Vanderbilt Journal of Transnational Law
Taxation of the worldwide income of U.S. citizens has been a feature of the U.S. income tax since the Revenue Act of 1913. This Article proposes that the United States abandon its imposition of income tax based on citizenship and institute a new system for taxing individuals based solely on residence. This includes (1) a revised definition of "residency status" that would be based on physical presence and be monitored through an entry-exit system, (2) a proposal for an exit tax imposed on termination of residence with respect to unrealized appreciation accrued during the period of residence, and (3) new …