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Articles 1 - 12 of 12
Full-Text Articles in Law
An Inquiry Into The Special Status Of Interest Payments, Michael J. Mcintyre
An Inquiry Into The Special Status Of Interest Payments, Michael J. Mcintyre
Duke Law Journal
No abstract provided.
California V. Grace Brethren Church, Lewis F. Powell Jr
California V. Grace Brethren Church, Lewis F. Powell Jr
Supreme Court Case Files
No abstract provided.
Merrion V. Jicarilla Apache Tribe, Lewis F. Powell Jr.
Merrion V. Jicarilla Apache Tribe, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
Ramah Navajo School Board V. Bureau Of Revenue Of New Mexico, Lewis F. Powell Jr.
Ramah Navajo School Board V. Bureau Of Revenue Of New Mexico, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
The Taxation Of Foreign Investment Income In Canada, The United States And Mexico, Glenn P. Jenkins, Devendranauth Misir, Graham Glenday
The Taxation Of Foreign Investment Income In Canada, The United States And Mexico, Glenn P. Jenkins, Devendranauth Misir, Graham Glenday
Law and Contemporary Problems
No abstract provided.
Capital Expenditures: A Result In Search Of A Rationale, John W. Lee, Nina R. Murphy
Capital Expenditures: A Result In Search Of A Rationale, John W. Lee, Nina R. Murphy
Faculty Publications
No abstract provided.
Tangling With Entanglement: Toward A Constitutional Evaluation Of Church-State Contacts, James A. Serritella
Tangling With Entanglement: Toward A Constitutional Evaluation Of Church-State Contacts, James A. Serritella
Law and Contemporary Problems
No abstract provided.
Dubious Interpretative Rules For Construing Federal Taxing Statutes, Richard A. Westin
Dubious Interpretative Rules For Construing Federal Taxing Statutes, Richard A. Westin
Law Faculty Scholarly Articles
Knowing even a substantial portion of the Internal Revenue Code of 1954 is a major achievement. Divining how the courts might react to a complex tax transaction is also terribly difficult, but for this ability lawyers are often well-rewarded on earth. The tools of this esoteric trade include a mass of interpretative rules of a most uncertain nature, as sophisticated tax advisors are well aware. This article discusses the application and limits of a litany of the interpretative rules. The rules are frequently applicable outside the tax field, but the following study is confined to their application to tax decisions. …
Partnership Taxation: A Deceased Partner's Final Year, Michelle A. Cecil
Partnership Taxation: A Deceased Partner's Final Year, Michelle A. Cecil
Faculty Publications
One significant and unresolved partnership taxation problem is the taxation of a deceased partner's final year. In a recent case of first impression, Estate of Hesse v. Commissioner, the Tax Court held that the widow of a deceased partner could not include his share of partnership losses incurred during the year of his death on their final joint income tax return. Consequently, the widow lost thousands of dollars in tax refunds because the loss deductions could not offset prior taxable income. The Tax Court believed the result was illogical and unfair, but nevertheless found that the Code required the decedent's …
Carryover Basis Repeal And Reform Of The Transfer Tax System, Russell K. Osgood
Carryover Basis Repeal And Reform Of The Transfer Tax System, Russell K. Osgood
Cornell Law Review
No abstract provided.
Comparative Analysis Of Systems Of Domestic Taxation Of Controlled Foreign Corporations, Jamie S. Martin, A. Dale Wilson
Comparative Analysis Of Systems Of Domestic Taxation Of Controlled Foreign Corporations, Jamie S. Martin, A. Dale Wilson
Vanderbilt Journal of Transnational Law
This Note outlines the existing law and practice of the domestic taxation of CFC's in the United States, United Kingdom, France, West Germany, and Japan, each of which exhibits a high level of economic and industrial advancement. United States developments are important because the statutory provisions of Subpart F have been adopted, with modifications, by other nations, including West Germany and Japan. The United Kingdom and France, on the other hand, have not yet adopted an integrated statutory scheme providing for domestic taxation of CFC's. These countries attack tax evasion schemes utilizing foreign controlled companies primarily through general laws, exchange …
Subpart F À La Française [French Attitude To Tax Havens], Hugh Ault, Philip Kaplan
Subpart F À La Française [French Attitude To Tax Havens], Hugh Ault, Philip Kaplan
Hugh J. Ault
No abstract provided.