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Articles 1 - 30 of 73
Full-Text Articles in Tax Law
Getting Serious About Curtailing Deferral Of Us Tax On Foreign Source Income, Robert J. Peroni, J. Clifton Fleming Jr., Stephen E. Shay
Getting Serious About Curtailing Deferral Of Us Tax On Foreign Source Income, Robert J. Peroni, J. Clifton Fleming Jr., Stephen E. Shay
Faculty Scholarship
When a U.S. person conducts business or investment activity abroad through a foreign corporation in a country that imposes only low rates of tax, the so-called deferral privilege allows the U.S. taxpayer to defer substantial amounts of U.S. tax at the cost of only a small foreign levy. Hence, the deferral privilege operates as a tax subsidy of sorts for U.S. persons with operations in low tax foreign countries and provides a major incentive for U.S. persons to shift their business operations and investments to foreign countries that impose little or no tax on the earnings of the foreign corporations.To …
U.S. Taxation Of Profits From Internet Software Sales - An Electronic Commerce Case Study, J. Clifton Fleming Jr.
U.S. Taxation Of Profits From Internet Software Sales - An Electronic Commerce Case Study, J. Clifton Fleming Jr.
Faculty Scholarship
No abstract provided.
The "Original Intent" Of The Federal Tax Treatment Of Private Pension Plans, James A. Wooten
The "Original Intent" Of The Federal Tax Treatment Of Private Pension Plans, James A. Wooten
Other Scholarship
No abstract provided.
Taxable And Tax-Free Acquisitions And Separations, Mark J. Silverman, Robert H. Wellen, Mark L. Yecies
Taxable And Tax-Free Acquisitions And Separations, Mark J. Silverman, Robert H. Wellen, Mark L. Yecies
William & Mary Annual Tax Conference
No abstract provided.
Selected Current Developments In Financial Accounting And Reporting, David W. Larue
Selected Current Developments In Financial Accounting And Reporting, David W. Larue
William & Mary Annual Tax Conference
No abstract provided.
Capitalization In The Nineties, Glenn R. Carrington
Capitalization In The Nineties, Glenn R. Carrington
William & Mary Annual Tax Conference
No abstract provided.
Federal And State Audit Issues, William L.S. Rowe, D. French Slaughter Iii
Federal And State Audit Issues, William L.S. Rowe, D. French Slaughter Iii
William & Mary Annual Tax Conference
No abstract provided.
Section 338(H)(10) & Appendix, Mark J. Silverman, Jonathan I. Forrest
Section 338(H)(10) & Appendix, Mark J. Silverman, Jonathan I. Forrest
William & Mary Annual Tax Conference
No abstract provided.
Use Of Limited Liability Companies In Corporate Transactions, Mark J. Silverman, Lisa M. Zarlenga
Use Of Limited Liability Companies In Corporate Transactions, Mark J. Silverman, Lisa M. Zarlenga
William & Mary Annual Tax Conference
No abstract provided.
Section 338(H)(10), Mark L. Yecies
Section 338(H)(10), Mark L. Yecies
William & Mary Annual Tax Conference
No abstract provided.
Contingent Consideration And Contingent Liabilities In Acquisitions: Outline,Addendum, References, Robert H. Wellen
Contingent Consideration And Contingent Liabilities In Acquisitions: Outline,Addendum, References, Robert H. Wellen
William & Mary Annual Tax Conference
No abstract provided.
Corporate Divisions Under Section 355, Mark J. Silverman
Corporate Divisions Under Section 355, Mark J. Silverman
William & Mary Annual Tax Conference
No abstract provided.
Bureau Of State Audits, Elisa D 'Angelo Weichel
Bureau Of State Audits, Elisa D 'Angelo Weichel
California Regulatory Law Reporter
No abstract provided.
The Influence Of Income Tax Rules On Insurance Reserves, David F. Bradford, Kyle D. Logue
The Influence Of Income Tax Rules On Insurance Reserves, David F. Bradford, Kyle D. Logue
Book Chapters
An insurance company is a financial intermediary whose main line of business is the sale of a particular type of contingent contract, called an insurance policy. Under this contract, the insurer promises to pay some amount to the policyholder, or to some other beneficiary, following the occurrence of an insured event. In the context of property-casualty insurance, the relevant insured events include, for example, the accidental destruction of the insured's property or the award of a liability judgment against the insured. In return for this promise the insured pays the insurer a premium. The premium and the earnings on the …
Racial Equality In The Twenty-First Century: What's Tax Policy Got To Do With It?, Dorothy A. Brown
Racial Equality In The Twenty-First Century: What's Tax Policy Got To Do With It?, Dorothy A. Brown
University of Arkansas at Little Rock Law Review
No abstract provided.
Setting An Agenda For The Study Of Tax And Black Culture, Beverly Moran
Setting An Agenda For The Study Of Tax And Black Culture, Beverly Moran
University of Arkansas at Little Rock Law Review
No abstract provided.
And The 1999 Award For The Worst Opinion In A Tax Case Goes To -, Deborah A. Geier
And The 1999 Award For The Worst Opinion In A Tax Case Goes To -, Deborah A. Geier
Law Faculty Articles and Essays
This article critiques the opinion in Owen v. United States by Judge Jerome Turner of the Western District of Tennessee.
Tax Lawyers, Ethical Obligations, And The Duty To The System, Watson
Tax Lawyers, Ethical Obligations, And The Duty To The System, Watson
Scholarly Works
Perhaps the most elusive area of law is that of legal ethics. While the term itself is easy to define,' the subject all but defies codification because ethics, or morals (the terms are interchangeable), cannot be encapsulated by or in law. This is because law, in general, contains its own standard of validity on which there is usually clear societal consensus. For example, murder, rape, and theft are morally repugnant universally. Hence, punishment for any of these offenses does not impinge upon religious or individual autonomy because there is no ethical freedom to choose whether or not to engage in …
The Fcc’S Minority Tax Certificate Program: A Proposal For Life After Death, Erwin G. Krasnow, Lisa M. Fowlkes
The Fcc’S Minority Tax Certificate Program: A Proposal For Life After Death, Erwin G. Krasnow, Lisa M. Fowlkes
Federal Communications Law Journal
In 1995, Congress eliminated the Federal Communications Commission’s (FCC) Minority Tax Certificate Program—a nonintrusive method of encouraging increased participation of minority entrepreneurs as owners in the broadcast and cable industries. Since that time, minorities have faced increased difficulties competing in all facets of the communications industry. These difficulties can be attributed to: (1) increased consolidation within the broadcast industry as a result of provisions of the Telecommunications Act of 1996 relaxing certain broadcast ownership limitations; (2) recent court decisions adverse to minority-specific programs; and (3) continued obstacles faced by minorities in accessing sufficient capital to acquire licenses and compete in …
The Value Of The Tax Certificate, Kofi Asiedu Ofori, Mark Lloyd
The Value Of The Tax Certificate, Kofi Asiedu Ofori, Mark Lloyd
Federal Communications Law Journal
Tax certificates are an example of successful incentive regulation. Prior to its repeal in 1995, section 1071 of the Internal Revenue Code permitted the tax-free sale or exchange of media properties to effectuate policies of the Federal Communications Commission. Enacted by Congress in 1943, this provision was originally used to soften the hardship created by involuntary sales of broadcast properties made necessary to reduce ownership concentration in the radio industry. In 1978, the tax certificate was used to promote goals to increase minority ownership of a variety of communications properties. This Article discusses the "value" of tax certificates as a …
Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey, Elyse G. Kirschner
Learning To Live With The New Foreign Nongrantor Trust Rules, Carlyn S. Mccaffrey, Elyse G. Kirschner
Vanderbilt Journal of Transnational Law
The Small Business Job Protection Act of 1996 (the 1996 Act) was intended to deal a heavy blow to the appeal of foreign trusts to U.S. persons. The results were mixed. On the one hand, the 1996 Act imposes an array of reporting requirements, imposes harsh penalties on failures to comply with these requirements, increases the interest charge imposed on taxes paid on distributions of accumulated income from foreign trusts, treats loans of cash from foreign trusts as distributions, and expands the kinds of gifts that can be treated as indirect transfers from foreign trusts. On the other hand, curiously, …
Ten Limitations To Ponder On Farm Limited Liability Companies, Jesse Richardson, L. Leon Geyer
Ten Limitations To Ponder On Farm Limited Liability Companies, Jesse Richardson, L. Leon Geyer
Law Faculty Scholarship
No abstract provided.
Corporate Nonrecognition Provisions: A Comparison Of The U.S. And Canadian Tax Regimes, Catherine Brown, Christine Manolakas
Corporate Nonrecognition Provisions: A Comparison Of The U.S. And Canadian Tax Regimes, Catherine Brown, Christine Manolakas
Dalhousie Law Journal
This article compares the rules governing the federal income taxation of corporate reorganizations in Canada with those in the United States, including transfers of property to a corporation, corporate divisions, share-for-share exchanges, amalgamations or mergers, recapitalizations, and corporate dissolutions. The paper outlines the provisions governing a particulartype of corporate transaction, compares the Canadian tax results with those of the United States, comments on any differences between particular tax provisions, and examines the practical implications of these differences. The authors conclude that although there are a number of parallels between the U.S. and Canadian tax systems, fundamental differences exist that change …
Education Expense Epiphanies, Malcolm L. Morris
Education Expense Epiphanies, Malcolm L. Morris
Buffalo Law Review
No abstract provided.
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance? (Symposium), Evelyn Brody
A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance? (Symposium), Evelyn Brody
All Faculty Scholarship
No abstract provided.
Charities In Tax Reform: Threats To Subsidies Overt And Covert, Evelyn Brody
Charities In Tax Reform: Threats To Subsidies Overt And Covert, Evelyn Brody
All Faculty Scholarship
Fundamental tax reform would do far more damage to charities than the obvious repeal of the deduction for charitable contributions. Over the decades, charities have quietly garnered billions of dollars worth of indirect benefits. For example, the largest tax expenditure - the exclusion from workers' income of employer-provided health insurance - has fattened nonprofit hospitals, and the new tuition tax credits promise to spur tuition inflation. Tax reform presents an opportunity to eliminate tax subsidies and enact any desired direct expenditures for specific public goods and activities. However, converting tax expenditures to direct outlays would likely take the form of …
Transfer Pricing, Anders Leif Allvin
Transfer Pricing, Anders Leif Allvin
LLM Theses and Essays
Transfer pricing is one of the principal international taxation issues of the 1990s and potentially of future decades as well. For corporate enterprises, it can be difficult enough to do business in just one country, but it gets even more complex when they go international. The growth of multinational enterprises (MNEs) creates complex taxation issues for both the tax administrations as well for the MNE. Transfer pricing concerns allocation of income earned within affiliated corporate groups in different countries, which must satisfy tax authorities that they are not evading taxes through the use of transfer pricing. The main problem with …
Economic Nexus: Legislative Presumption Or Legitimate Proposition?, Craig J. Langstraat, Emily S. Lemmon
Economic Nexus: Legislative Presumption Or Legitimate Proposition?, Craig J. Langstraat, Emily S. Lemmon
Akron Tax Journal
This article discusses the theory of economic nexus, the present nexus conditions in various states, and the constitutional issues surrounding nexus. These constitutional issues will then be applied to the theory of economic nexus in order to draw conclusions concerning the constitutionality and feasibility of this theory.
"Employee Stock Ownership Plans: Uncertainties Plaguing The Duties Of The Esop Fiduciary With Respect To Voting And Defensive Esops", Gina Marie Agresta-Richardson
"Employee Stock Ownership Plans: Uncertainties Plaguing The Duties Of The Esop Fiduciary With Respect To Voting And Defensive Esops", Gina Marie Agresta-Richardson
Akron Tax Journal
This article will examine two particular dilemmas that challenge ESOP fiduciaries: voting rights and the use of defensive ESOPs. First, this article will discuss the development of ESOPs and their general mechanics. Second, it will explore the creation of ERISA, including the policy behind the statutory scheme. It will then set forth ERISA fiduciary law, noting the interplay of ERISA fiduciary standards and trust law. Third, this article will address problems confronting the ESOP fiduciary, specifically, voting and tendering shares of ESOP stock and the effect of using an ESOP as an anti-takeover device. In doing so, this article will …
Entrenching Interests: State Supermajority Requirements To Raise Taxes, Max Minzner
Entrenching Interests: State Supermajority Requirements To Raise Taxes, Max Minzner
Akron Tax Journal
This article attempts to answer the question of supermajority design. If alterations in the tax code are to be restricted, how should they be limited? To what type of bills should a supermajority requirement apply? At what level should the requirement be implemented? When and how should the legislature be allowed to avoid the rule? Part II discusses the current House rule and considers why it was imposed, whether or not it is constitutional, and the effect the rule has had in practice. Part III moves to the states' experiences with supermajority requirements, and examines both the de jure limitations …