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Articles 1 - 9 of 9

Full-Text Articles in Law

Living With Transparency, Robert D. Probasco Nov 2008

Living With Transparency, Robert D. Probasco

Robert Probasco

No abstract provided.


The Mortgage Forgiveness Debt Relief Act Of 2007: Two New Provisions Regarding Principal Residence, Kristin Balding Gutting Oct 2008

The Mortgage Forgiveness Debt Relief Act Of 2007: Two New Provisions Regarding Principal Residence, Kristin Balding Gutting

Kristin Balding Gutting

No abstract provided.


Shelf Project: Amended Returns -- Imposing A Duty To Correct Material Mistakes, T. Keith Fogg, Calvin H. Johnson Sep 2008

Shelf Project: Amended Returns -- Imposing A Duty To Correct Material Mistakes, T. Keith Fogg, Calvin H. Johnson

T. Keith Fogg

The amended returns proposal would create a duty for a taxpayer to correct material factual errors on its tax return when the error is discovered. Failure to correct an erroneous but innocent representation is considered to be a form of deceit in American tort and contract law.


Shelf Project: National Tax Lien Registry, T. Fogg Aug 2008

Shelf Project: National Tax Lien Registry, T. Fogg

T. Keith Fogg

The current system for filing a notice of federal tax lien came into existence before the electronic age. It relies on myriad state laws and the filing of notices in localities more than 4,100 in all. The current system hurts both the IRS and taxpayers by requiring multiple filings and, thus, multiple removals when the underlying obligation is paid or discharged. With increasing complexity comes increasing costs and errors for the IRS, taxpayers, and taxpayers' creditors. A single Web-based system would be cheaper and more efficient. That possibility drives this recommendation.


Japanese Cfc Rules Consistent With Treaty, Court Holds, Hugh Ault, Mitsuhiro Honda Mar 2008

Japanese Cfc Rules Consistent With Treaty, Court Holds, Hugh Ault, Mitsuhiro Honda

Hugh J. Ault

In a practice article, Mitsuhiro Honda and Hugh J. Ault comment on a Tokyo High Court ruling that held that Japan's controlled foreign corporation rules are consistent with article 7(1) of the Japan-Singapore tax treaty.


Retention Requirements For Tax Records, Robert D. Probasco Jan 2008

Retention Requirements For Tax Records, Robert D. Probasco

Robert Probasco

No abstract provided.


Current Developments In Procedures For The Resolution Of International Tax Disputes, Hugh Ault Dec 2007

Current Developments In Procedures For The Resolution Of International Tax Disputes, Hugh Ault

Hugh J. Ault

No abstract provided.


Changing Tradeoffs Confront Employee-Shareholders Who Want To Access Corporate Profits, Richard Winchester Dec 2007

Changing Tradeoffs Confront Employee-Shareholders Who Want To Access Corporate Profits, Richard Winchester

Richard Winchester

No abstract provided.


Equity Undermined: The 1918 Check-The-Box Entity Classification Election, Richard Winchester Dec 2007

Equity Undermined: The 1918 Check-The-Box Entity Classification Election, Richard Winchester

Richard Winchester

No abstract provided.