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Articles 391 - 420 of 434
Full-Text Articles in Tax Law
Tax Policy V. Revenue Policy: Qualified Plans, Tax Expenditures, And The Flat, Plan Level Tax, Edward A. Zelinsky
Tax Policy V. Revenue Policy: Qualified Plans, Tax Expenditures, And The Flat, Plan Level Tax, Edward A. Zelinsky
Articles
No abstract provided.
The Merger Puzzle, John A. Miller
Liars Should Have Good Memories: Legal Fictions And The Tax Code, John A. Miller
Liars Should Have Good Memories: Legal Fictions And The Tax Code, John A. Miller
Articles
No abstract provided.
Indeterminacy, Complexity, And Fairness: Justifying Rule Simplification In The Law Of Taxation, John A. Miller
Indeterminacy, Complexity, And Fairness: Justifying Rule Simplification In The Law Of Taxation, John A. Miller
Articles
No abstract provided.
Rationalizing Injustice: The Supreme Court And The Property Tax, John A. Miller
Rationalizing Injustice: The Supreme Court And The Property Tax, John A. Miller
Articles
No abstract provided.
Reform Of The Taxation Of Mergers, Acquisitions, And Lbos, John A. Miller
Reform Of The Taxation Of Mergers, Acquisitions, And Lbos, John A. Miller
Articles
No abstract provided.
Section 902 Is Too Generous, George Mundstock
Compensatory And Punitive Damages For A Personal Injury: To Tax Or Not To Tax, Douglas A. Kahn
Compensatory And Punitive Damages For A Personal Injury: To Tax Or Not To Tax, Douglas A. Kahn
Articles
Since the adoption in 1919 of the Revenue Act of 1918, damages received on account of personal injuries or sickness have been excluded by statute from gross income.1 This exclusion, which does not apply to reimbursements for medical expenses for which the taxpayer was previously allowed a tax deduction,2 is presently set forth in section 104(a)(2). One might expect that a provision having recently attained the ripe age of 75 years without change in its basic language would have a settled meaning. However, recent litigation under section 104(a)(2) bristles with unsettled issues. Does the exclusion apply to punitive damages? To …
Taxation Of Business Rent, George Mundstock
Qualified Plans And Identifying Tax Expenditures: A Rejoinder To Professor Stein, Edward A. Zelinsky
Qualified Plans And Identifying Tax Expenditures: A Rejoinder To Professor Stein, Edward A. Zelinsky
Articles
No abstract provided.
Community Income, Federal Income Taxation And Divorce, John A. Miller
Community Income, Federal Income Taxation And Divorce, John A. Miller
Articles
No abstract provided.
Lost On A One-Way Street: The Taxpayer's Ability To Disavow Form, William S. Blatt
Lost On A One-Way Street: The Taxpayer's Ability To Disavow Form, William S. Blatt
Articles
No abstract provided.
Greenmail, Golden Parachutes And The Internal Revenue Code: A Tax Policy Critique Of Sections 280g, 4999 And 5881, Edward A. Zelinsky
Greenmail, Golden Parachutes And The Internal Revenue Code: A Tax Policy Critique Of Sections 280g, 4999 And 5881, Edward A. Zelinsky
Articles
No abstract provided.
The Two Faces Of Tax Neutrality: Do They Interact Or Are They Mutually Exclusive?, Douglas A. Kahn
The Two Faces Of Tax Neutrality: Do They Interact Or Are They Mutually Exclusive?, Douglas A. Kahn
Articles
The term "tax neutrality" refers to at least two quite different concepts. In its most common usage, tax neutrality refers to tax provisions that conform to an ideal tax system. A tax provision that is consistent with such an ideal system is described as "neutral." A tax provision that cannot be reconciled with the ideal system is sometimes referred to as a "tax expenditure" item. I will discuss tax expenditures later in this paper.
The Direct Investment Tax Initiatives Of The European Community: A View From The United States, Stanley I. Langbein, David H. Rosenbloom
The Direct Investment Tax Initiatives Of The European Community: A View From The United States, Stanley I. Langbein, David H. Rosenbloom
Articles
No abstract provided.
The Latest Turn Of The Screw In Estate Planning: The Legislative Attack On Disproportionate Transfers, John A. Miller
The Latest Turn Of The Screw In Estate Planning: The Legislative Attack On Disproportionate Transfers, John A. Miller
Articles
No abstract provided.
State Administration Of A National Sales Tax: A New Opportunity For Cooperative Federalism, John A. Miller
State Administration Of A National Sales Tax: A New Opportunity For Cooperative Federalism, John A. Miller
Articles
No abstract provided.
Taxation And U.S. Multinational Investment, James R. Hines Jr.
Taxation And U.S. Multinational Investment, James R. Hines Jr.
Articles
In 1985, nonbank U.S. multinational companies employed 24.5 million workers, had worldwide sales of almost $3.5 trillion, and net income of $150 billion on assets of $4.2 trillion. The foreign (non-U.S.) affiliates of these companies had 6.4 million employees, $900 billion of those sales, and $43 billion of net income, with assets of $838 billion. United States multinationals accounted for roughly three-quarters of total American merchandise exports in 1985 and half of total imports, with approximately 40 percent of each category arising from transfers within U.S. multinationals between American parent firms and their own foreign affiliates. And 1985 is widely …
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Articles
The General Utilities doctrine is the name given to the now largely defunct tax rule that a corporation does not recognize a gain or a loss on making a liquidating or nonliquidating distribution of an appreciated or depreciated asset to its shareholders. The roots of the doctrine, can be traced to a regulation promulgated in 1919 that denied realization of gain or loss to a corporation when making a liquidating distribution of an asset in kind. No regulatory provision existed which specified the extent to which realization would or would not be triggered by a nonliquidating distribution such as a …
The Tax Treatment Of Qualified Plans: A Classic Defense Of The Status Quo, Edward A. Zelinsky
The Tax Treatment Of Qualified Plans: A Classic Defense Of The Status Quo, Edward A. Zelinsky
Articles
The current tax treatment of qualified pension and profit sharing plans has been criticized by commentators as an unfair and expensive tax expenditure. In this Article, Professor Zelinsky challenges this characterization and defends the current treatment of qualified plans on the ground that it is at least as attractive as its alternatives and superior to many of them. After evaluating the current treatment and the alternatives under the criteria of measurability, administrability, liquidity, equity, and simplicity, Professor Zelinsky concludes that the present treatment of qualified plans can be viewed as an acceptable part of a normative income tax.
The Low-Income Housing Tax Credit: A Poor Solution To The Housing Crisis, Janet Stearns
The Low-Income Housing Tax Credit: A Poor Solution To The Housing Crisis, Janet Stearns
Articles
No abstract provided.
The Tax Reform Act Of 1986: A Response To Professor Yorio And His Vision Of The Future Of The Internal Revenue Code, Edward A. Zelinsky
The Tax Reform Act Of 1986: A Response To Professor Yorio And His Vision Of The Future Of The Internal Revenue Code, Edward A. Zelinsky
Articles
No abstract provided.
The Deductibility Of State And Local Taxes: Income Measurement, Tax Expenditures And Partial, Functional Deductibility, Edward A. Zelinsky
The Deductibility Of State And Local Taxes: Income Measurement, Tax Expenditures And Partial, Functional Deductibility, Edward A. Zelinsky
Articles
No abstract provided.
Taxation Of Business Intangible Capital, George Mundstock
Taxation Of Business Intangible Capital, George Mundstock
Articles
No abstract provided.
Efficiency And Income Taxes: The Rehabilitation Of Tax Incentives, Edward A. Zelinsky
Efficiency And Income Taxes: The Rehabilitation Of Tax Incentives, Edward A. Zelinsky
Articles
This Article explores two prominent issues in current legal literature: the propriety of tax incentives in the federal income tax and the use of economic analysis to examine questions of concern to academic lawyers. One premise of this Article is that there is a connection between these two topics.
The Federal Circuit's 1985 Tax Cases: The Exercise Of Equity, William S. Blatt
The Federal Circuit's 1985 Tax Cases: The Exercise Of Equity, William S. Blatt
Articles
No abstract provided.
The Supreme Court's Misconstruction Of A Procedural Statute-A Critique Of The Court's Decision In Badaracco, Douglas A. Kahn
The Supreme Court's Misconstruction Of A Procedural Statute-A Critique Of The Court's Decision In Badaracco, Douglas A. Kahn
Articles
When a taxpayer files an honest' federal income tax return for a taxable year, section 6501(a) of the Internal Revenue Code2 limits the period of time during which the Government can assess a tax for that year to a three-year period commencing with the date that the return was filed. The three-year limitations period is extended for an additional three years by section 6501(e)(1)(A) if the taxpayer's return omits properly includible gross income in an amount in excess of twenty-five percent of the gross income that was reported. If a taxpayer fails to file a return for a taxable year …
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Articles
If several persons wish to join together in a common enterprise in order to pool their capital or labor or some of each, they may choose among a variety of available organizational structures that will serve that purpose. The most common entity forms are partnerships (including joint ventures), corporations, and trusts. While, in its typical structure, each of those entity forms has its own distinct characteristics, the structure of such organizations often is modified by agreement so as to adopt attributes of another type of entity. Because of this, the substantive distinction between entity types is blurred.
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Articles
No abstract provided.
Comments On 'Tax Neutrality Between Equity Capital And Debt', Douglas A. Kahn
Comments On 'Tax Neutrality Between Equity Capital And Debt', Douglas A. Kahn
Articles
Professor Andrews' proposals are aimed at eliminating a tax bias that affects a corporation's choice of a method of raising additional capital. Professor Andrews believes that the current tax system favors a corporation which raises capital internally by accumulating its income (or by borrowing) rather than by issuing stock. Professor Andrews seeks a neutral system that permits the choice of the manner in which capital is raised to be made on economic grounds without influence of the tax laws.