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Articles 31 - 60 of 76

Full-Text Articles in Taxation-Federal

Deferral: Consider Ending It Instead Of Expanding It, J. Clifton Fleming Jr. Dec 2000

Deferral: Consider Ending It Instead Of Expanding It, J. Clifton Fleming Jr.

Faculty Scholarship

No abstract provided.


Preslar V. Commissioner: Debt-Discharge Income And Its Rationale, Chad J. Pomeroy Nov 2000

Preslar V. Commissioner: Debt-Discharge Income And Its Rationale, Chad J. Pomeroy

BYU Law Review

No abstract provided.


Getting Serious About Curtailing Deferral Of Us Tax On Foreign Source Income, Robert J. Peroni, J. Clifton Fleming Jr., Stephen E. Shay Dec 1999

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. Dec 1999

U.S. Taxation Of Profits From Internet Software Sales - An Electronic Commerce Case Study, J. Clifton Fleming Jr.

Faculty Scholarship

No abstract provided.


The Deceptively Disparate Treatment Of Business And Investment Interest Expense Under A Cash-Flow Consumption Tax And A Schanz-Haig-Simons Income Tax, J. Clifton Fleming, Jr. Dec 1997

The Deceptively Disparate Treatment Of Business And Investment Interest Expense Under A Cash-Flow Consumption Tax And A Schanz-Haig-Simons Income Tax, J. Clifton Fleming, Jr.

Faculty Scholarship

No abstract provided.


Ending The Irs As We Know It: Thoughts From Outside The Beltway, J. Clifton Fleming Jr. Dec 1996

Ending The Irs As We Know It: Thoughts From Outside The Beltway, J. Clifton Fleming Jr.

Faculty Scholarship

No abstract provided.


Section L04(A)(2) After Commissioner U. Schleier: Litigating The Excludability Of Statutory Damages "Received On Account Of Personal Injuries", T. James Lee Jr. May 1996

Section L04(A)(2) After Commissioner U. Schleier: Litigating The Excludability Of Statutory Damages "Received On Account Of Personal Injuries", T. James Lee Jr.

BYU Law Review

No abstract provided.


Scoping Out The Uncertain Simplification (Complication?) Effects Of Vats, Bats, And Consumed Income Taxes, J. Clifton Fleming Jr. Dec 1995

Scoping Out The Uncertain Simplification (Complication?) Effects Of Vats, Bats, And Consumed Income Taxes, J. Clifton Fleming Jr.

Faculty Scholarship

No abstract provided.


Stock Redemptions And The Family-Owned Corporation: Tax Traps Oll The Path To Capital Gain Treatment, Scott E. Copple Nov 1995

Stock Redemptions And The Family-Owned Corporation: Tax Traps Oll The Path To Capital Gain Treatment, Scott E. Copple

BYU Law Review

No abstract provided.


A Second Look At The Zero Basis Hoax, J. Clifton Fleming Jr. Dec 1994

A Second Look At The Zero Basis Hoax, J. Clifton Fleming Jr.

Faculty Scholarship

No abstract provided.


Taxes, Morals, And Legitimacy, Leo P. Martinez Sep 1994

Taxes, Morals, And Legitimacy, Leo P. Martinez

BYU Law Review

No abstract provided.


Determining An Individual's Federal Income Tax Liability When The Tax Benefit Rule Applies: A Fifty-Year Checkup Brings A New Prescription For Calculating Gross, Adjusted Gross, And Taxable Incomes, Matthew J. Barrett Mar 1994

Determining An Individual's Federal Income Tax Liability When The Tax Benefit Rule Applies: A Fifty-Year Checkup Brings A New Prescription For Calculating Gross, Adjusted Gross, And Taxable Incomes, Matthew J. Barrett

BYU Law Review

No abstract provided.


The Ethics Reform Act Of 1989: Why The Taxman Can't Be A Paperback Writer, David A. Golden May 1991

The Ethics Reform Act Of 1989: Why The Taxman Can't Be A Paperback Writer, David A. Golden

BYU Law Review

No abstract provided.


Begier V. Irs, Guy Lamoyne Black Mar 1991

Begier V. Irs, Guy Lamoyne Black

Brigham Young University Journal of Public Law

No abstract provided.


Davis V. Michigan And The Doctrine Of Retroactivity: States' Refund Liability For Taxation Of Federal Pension Income, Timothy B. Sherman May 1990

Davis V. Michigan And The Doctrine Of Retroactivity: States' Refund Liability For Taxation Of Federal Pension Income, Timothy B. Sherman

Brigham Young University Journal of Public Law

No abstract provided.


Tax Deductions For Payments To Mormon Missionaries, K. C. Jensen Mar 1990

Tax Deductions For Payments To Mormon Missionaries, K. C. Jensen

Brigham Young University Journal of Public Law

No abstract provided.


Jurisdiction Over Civil Tax Cases, Larry Kramer Mar 1990

Jurisdiction Over Civil Tax Cases, Larry Kramer

BYU Law Review

No abstract provided.


Problem Areas Under Internal Revenue Code Section 704(E): The Family Partnership Revisited, Gerald T. Snow Mar 1989

Problem Areas Under Internal Revenue Code Section 704(E): The Family Partnership Revisited, Gerald T. Snow

Brigham Young University Journal of Public Law

No abstract provided.


Abortion Politics: The Roman Catholic Church's Tax-Exempt Status In Jeopardy Under Section 501(C)(3) Of The Internal Revenue Code, Junji John Shimazaki Nov 1988

Abortion Politics: The Roman Catholic Church's Tax-Exempt Status In Jeopardy Under Section 501(C)(3) Of The Internal Revenue Code, Junji John Shimazaki

BYU Law Review

No abstract provided.


Is It Really Reform? A Theoretical Overview Of The 1986 Tax Reform Act, Daniel L. Simmons Mar 1987

Is It Really Reform? A Theoretical Overview Of The 1986 Tax Reform Act, Daniel L. Simmons

BYU Law Review

No abstract provided.


Overturning Bellas Hess: Due Process Considerations, Sandra B. Mccray May 1985

Overturning Bellas Hess: Due Process Considerations, Sandra B. Mccray

BYU Law Review

No abstract provided.


Internal Revenue Code Section 414(N): Congressional Authorization To Discriminate Among Retirement Plan Participants, David A. Channer Mar 1985

Internal Revenue Code Section 414(N): Congressional Authorization To Discriminate Among Retirement Plan Participants, David A. Channer

BYU Law Review

No abstract provided.


Rca Corp. V. United States: The Latest Round In The Controversy Over Actrual Accounting For Prepaid Income, R. Glen Woods Nov 1983

Rca Corp. V. United States: The Latest Round In The Controversy Over Actrual Accounting For Prepaid Income, R. Glen Woods

BYU Law Review

No abstract provided.


Lobbying Restriction On Section 501(C)(3) Organizations Held Unconstitutional: First Amendment Implications Of Taxation With Representation Of Washington V. Regan, Karen B. Crockett May 1983

Lobbying Restriction On Section 501(C)(3) Organizations Held Unconstitutional: First Amendment Implications Of Taxation With Representation Of Washington V. Regan, Karen B. Crockett

BYU Law Review

No abstract provided.


An Inequitable Jury Instruction On The Taxability Of Personal Injury Damage Awards: Blanchfield V. Dennis, Thomas D. Boyle Mar 1983

An Inequitable Jury Instruction On The Taxability Of Personal Injury Damage Awards: Blanchfield V. Dennis, Thomas D. Boyle

BYU Law Review

No abstract provided.


The Continuing Controversy Over Crane's Footnote 37: Tufts V. Commissioner, S. Robert Bradley Sep 1982

The Continuing Controversy Over Crane's Footnote 37: Tufts V. Commissioner, S. Robert Bradley

BYU Law Review

No abstract provided.


Revocation Of Tax-Exempt Status Of Religious Schools-Conflict With The Religion Clauses Of The First Amendment: Bob Jones University V. United States, R. Clyde Parker Jr. Nov 1981

Revocation Of Tax-Exempt Status Of Religious Schools-Conflict With The Religion Clauses Of The First Amendment: Bob Jones University V. United States, R. Clyde Parker Jr.

BYU Law Review

No abstract provided.


A Substance-Oriented Approach To The Boot-Netting Rules Under Section 1031 Of The Internal Revenue Code: Biggs V. Commissioner, Gregory Clark Newton May 1981

A Substance-Oriented Approach To The Boot-Netting Rules Under Section 1031 Of The Internal Revenue Code: Biggs V. Commissioner, Gregory Clark Newton

BYU Law Review

No abstract provided.


The Unfinished Business Of Section 1244: Removing The Remaining Traps, J. Clifton Fleming Jr. Dec 1980

The Unfinished Business Of Section 1244: Removing The Remaining Traps, J. Clifton Fleming Jr.

Faculty Scholarship

No abstract provided.


Congressional Sanction Of Illicit Cohabitation- The Tax Reform Act Of 1969, James L. Musselman Nov 1979

Congressional Sanction Of Illicit Cohabitation- The Tax Reform Act Of 1969, James L. Musselman

BYU Law Review

No abstract provided.