Tax Law Commons^™

Highway Robbery: The Eleventh Circuit Correctly Finds Fbar Willful-Violation Penalties Subject To The Eighth Amendment In United States V. Schwarzbaum, Claire Borland

Villanova Law Review (1956 - )

No abstract provided.

Private Equity And The Gridiron: Tax Considerations In Secondary Sales Of Nfl Investments, Harrison Penn Nugent

Jeffrey S. Moorad Sports Law Journal (1994 - )

No abstract provided.

Protecting Dependent Children In Bankruptcy, Michael D. Sousa, L. Alexis Whitley Esq.

Villanova Law Review (1956 - )

No abstract provided.

Fiscal And Foreign Relations Dimensions Of Financial Stability Regulation, Ilya Beylin

Villanova Law Review (1956 - )

No abstract provided.

Perverse Tax Incentives And The Destruction Of Creative Works, Luke Maher

Villanova Law Review (1956 - )

No abstract provided.

Transformative Technology And Shortening The Statute Of Limitations Applicable To Taxpayers, Jay A. Soled, Leslie Book

Faculty Publications

When it comes to submitting tax returns and paying taxes, most taxpayers understand the nature of their civic duties and do so dutifully, if not willingly. However, many taxpayers fail to grasp why the IRS has such an elongated time period—namely, three years— to audit their tax returns and propose an assessment. Indeed, when the IRS exercises its oversight authority, records may no longer be available, and memories may be dulled.

Since the original institution of the three-year tax assessment limitations period nearly a century ago, tremendous technological strides have been made. Indeed, over ninety percent of income tax returns …

Book Review: Untaxed: The Rich, The Irs,And A New Approach To Tax Compliance, Leslie Book

Faculty Publications

No abstract provided.

Squeezing Blood From Stones? A Comparative Analysis Of Tax Relief For Victim-Survivors In Australia And The United States, Christine Speidel, Leslie Book, Ann Kayis-Kumar

Faculty Publications

Women who leave abusive relationships generally do so with increased debt, reduced assets, insecure housing and longer-term economic insecurity. Most of these women will be experiencing economic abuse even after the relationship has ended, and many cite financial instability as a key factor driving them back into abusive relationships. So, it is imperative that the tax and transfer system helps rather than hinders (albeit inadvertently) this cohort of financially vulnerable taxpayers. However, this is not always the case, with victim-survivors of economic abuse often liable for tax debts incurred by former partners operating businesses in the victim-survivor's name.

This article …

Identifying And Supporting Financially Vulnerable Women Experiencing Economic Abuse: A Grounded Theory Approach, Leslie Book, Ann Kayis-Kumar, Youngdeok Lim, Jack Noone, Michael Walpole, Jan Breckenridge

Faculty Publications

This study extends the literature by exploring the role of pro bono tax clinics within the social impact ecosystem with a focus on the experiences of women in financial distress who are otherwise unable to access professional tax advice. Using clinic data derived from a pro bono tax advisory clinic, this article finds that 58 per cent of financially vulnerable women seeking pro bono tax services have experienced domestic and family violence (DFV), confirming again the link between financial stress and economic abuse. Yet only 3 per cent of these women were receiving domestic and family violence-related support, highlighting the …

On The Fence About Immigration And Overpopulation: "Environmentalists" Challenge Dhs Policies On Nepa Basis In Whitewater Draw Natural Resource Conservation District V. Mayorkas, Maya J. Williams

Villanova Environmental Law Journal (1991 - )

No abstract provided.

Collection Due Process At Twenty-Five: A Still Important And Needed Check On Irs Collection, Leslie Book

Faculty Publications

No abstract provided.

The Mechanics Of Share Repurchases Or How I Stopped Worrying And Learned To Love Stock Buybacks, Richard A. Booth

Faculty Publications

Stock repurchases by issuing corporations have always been controversial. They have become even more so recently because of the perception that the excess funds used to finance them have come from tax cuts and other sources (such as government bailouts) that were intended to stimulate reinvestment or enhanced wages and benefits for workers. As a result, critics have proposed amendments to tax law that discourage buybacks (and possibly dividends as well). The theory is that the benefits of such distributions go mostly to executives (who are compensated in large part with equity) and to already wealthy stockholders. The controversy is …

Reducing Administrative Burdens To Protect Taxpayer Rights, Leslie Book, T. Keith Fogg, Nina E. Olson

Faculty Publications

The tax system designed by Congress imposes significant administrative burdens on taxpayers. IRS decisions regarding how it administers tax laws can add to congressionally imposed burdens. The administrative burdens are consequential and hurt some people, especially lower- or moderate- income individual taxpayers, more than others. While the IRS strives to measure and reduce the time and money taxpayers spend to comply with their tax obligations, it does not consider the effect administrative burdens have on taxpayer rights, including the right to be informed, the right to pay no more than the correct amount of tax, and the right to a …

The Strange And Curious Tax Treatment Of Investment Expenses, Jay A. Soled, Mallory A. Morris

Villanova Law Review (1956 - )

No abstract provided.

Workplace Transformation And Its Tax Compliance Implications, Jay A. Soled

Villanova Law Review (1956 - )

No abstract provided.

Puff, Puff, Tax: Internal Revenue Code Section 280e Penalizes State-Sanctioned Marijuana Companies And Undermines The Ability-To-Pay Principle, Joseph E. Thomas

Villanova Law Review (1956 - )

No abstract provided.

Tax Administration And Racial Justice: The Illegal Denial Of Tax Based Pandemic Relief To The Nation's Incarcerated, Leslie Book

Faculty Publications

No abstract provided.

Does Tax Matter? Evidence On Executive Compensation After 162(M)'S Repeal, Andrew Lund, Brian Galle, Gregg D. Polsky

Faculty Publications

No abstract provided.

Difficulty Of Care: Alligning Tax And Health Care Policy For Family Caregiving, Christine S. Speidel

Faculty Publications

In the United States millions of people live with disabilities, many of whom require assistance with activities of daily life to remain in their homes and communities. However, financial support for this assistance is limited. Many caregivers forgo working outside the home in order to provide care to a family member. And while state and federal programs provide some compensation for caregiving, caregivers frequently face problems including poverty, lack of health insurance, lack of Social Security and Medicare credits, and lack of retirement savings. Our nation’s paltry support for caregiving threatens the practical ability of people with disabilities to choose …

Tax Practice Gets A Mary Kay Makeover: The Tale Of Peterson And The Danielson Rule, Joy Sabino Mullane

Faculty Publications

No abstract provided.

Social Justice And The Low-Income Taxpayer, W. Edward Afield

Villanova Law Review (1956 - )

No abstract provided.

Pandora's Box Enters The Batter's Box: How The Tax Cuts And Jobs Act's Unintended Consequence Places Mlb, And All North American Leagues, In Tax Chaos, Kari Smoker, Alan Pogroszewski, Kyle Stich, Kevin Arnold

Jeffrey S. Moorad Sports Law Journal (1994 - )

No abstract provided.

Giving Taxpayer Rights A Seat At The Table, Leslie Book

Faculty Publications

How can Congress’s codification of the Taxpayer Bill of Rights (TBOR) make a meaningful difference in tax administration? This question will likely confront academics, policymakers, and judges in the coming years. In late 2015, Congress codified the rights that the Internal Revenue Service (IRS) administratively adopted in 2014, explicitly requiring that the Commissioner ensure that IRS employees receive training and act in accord with the codified rights. A recent article by Professors Alice Abreu and Richard Greenstein refers to the codification of TBOR as having the power to “transform the tax practice and the relationship between taxpayers and the IRS.” …

"Works For Me": What's Next For Pennsylvania Corporate Tax Liabilities After Nextel Communications Of The Mid-Atlantic V. Commonwealth, Riley Bauer

Villanova Law Review (1956 - )

No abstract provided.

Should Apb 23 Indefinite Reinvestment Be Repealed?, J. Richard Harvey

Working Paper Series

A recent letter to FASB suggested that APB 23 should be repealed. Although there is a clear lack of application guidance surrounding APB 23, repeal is not justified. Instead, FASB should address several practical uncertainties that have effectively allowed U.S. MNCs to make whatever APB 23 assumption best suits their needs.

Given that many U.S. MNCs have shifted substantial amounts of income to low-tax foreign jurisdictions and may need those foreign earnings back in the U.S. relatively soon, it is important for FASB to address these issues. If not, aggressive MNCs may continue to assert indefinite reinvestment when in fact …

Martin Luther King, Jr. Lecture - "Skin In The Tax Game": Invisible Taxpayers? Invisible Citizens?, Mildred Wigfall Robinson

Villanova Law Review (1956 - )

No abstract provided.

Tax Evaded In The Federal Tax Crimes Sentencing Process And Beyond, John A. Townsend

Villanova Law Review (1956 - )

No abstract provided.

Clash For Cash: The Conflict Over Tax Whistleblower Contracts, Jeremiah Coder

Villanova Law Review (1956 - )

No abstract provided.

Loving V. Irs: The Treasury Department's Authority To Regulate Tax Return Preparation Conduct Of Commercial Return Preparers, Lawrence B. Gibbs

Villanova Law Review (1956 - )

No abstract provided.

Loving And Legitimacy: Irs Regulation Of Tax Return Preparation, Steve R. Johnson

Villanova Law Review (1956 - )

No abstract provided.