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Articles 91 - 120 of 179
Full-Text Articles in Taxation-Federal
Doping Out The Capitalization Rules After Indopco, John W. Lee
Doping Out The Capitalization Rules After Indopco, John W. Lee
Faculty Publications
In this article, Lee provides guidance for Treasury and the IRS (in their promised clarification of application of INDOPCO). He delineates how to avoid what he perceives as the past pitfalls of capitalization of recurring, insubstantial, or relatively short-lived expenditures with Ito, or inadequate, amortization. The article also sets forth models for (a) amortizing as. a freestanding deferred charge long-lived substantial self-created intangibles such as business expansion costs, including employee training costs, and (b) expensing, or perhaps better, amortizing currently less substantial or regularly recurring, steady state self-created intangibles (such as repairs and advertising, respectively).
Recent Developments In The Income Taxation Of Individuals, Partnerships, Estates, & Trusts, Meade Emory
Recent Developments In The Income Taxation Of Individuals, Partnerships, Estates, & Trusts, Meade Emory
William & Mary Annual Tax Conference
No abstract provided.
And The Rebuttal, Glenn E. Coven
Redefining Debt: Of Indianapolis Power And Fictitious Interest, Glenn E. Coven
Redefining Debt: Of Indianapolis Power And Fictitious Interest, Glenn E. Coven
Faculty Publications
No abstract provided.
Living With Passive Losses - A Practival Approach, Richard M. Lipton
Living With Passive Losses - A Practival Approach, Richard M. Lipton
William & Mary Annual Tax Conference
No abstract provided.
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, David H. Pogue, Richard E. Levine, Todd Wallace
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, David H. Pogue, Richard E. Levine, Todd Wallace
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments In Federal Income Taxation, Ira B. Shepard
Recent Developments In Federal Income Taxation, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner
Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner
William & Mary Annual Tax Conference
No abstract provided.
Chaos In Wonderland: A Review Of The Regulations Issued Under Irc Section 89, Rebecca J. Miller
Chaos In Wonderland: A Review Of The Regulations Issued Under Irc Section 89, Rebecca J. Miller
William & Mary Annual Tax Conference
No abstract provided.
Taxpayer Bill Of Rights, Lawrence B. Gibbs
Taxpayer Bill Of Rights, Lawrence B. Gibbs
William & Mary Annual Tax Conference
No abstract provided.
Tax Aspects Of Divorce And Separation: Alimony, Child Support And Property Transfers, Robert E. Lee
Tax Aspects Of Divorce And Separation: Alimony, Child Support And Property Transfers, Robert E. Lee
William & Mary Annual Tax Conference
No abstract provided.
The Art Of Regulation Drafting: Structured Discretionary Justice Under Section 355, John W. Lee
The Art Of Regulation Drafting: Structured Discretionary Justice Under Section 355, John W. Lee
Faculty Publications
This article analyzes the 35-year evolution of the section 355 regulations from the perspectives of the jurisprudential dichotomy between general principles and detailed rules and administrative law theory as to agency discretion.
Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer
Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer
William & Mary Law Review
No abstract provided.
Aftermath Of The 1986 Tax Reform Act- Part Ii, Louis H. Diamond
Aftermath Of The 1986 Tax Reform Act- Part Ii, Louis H. Diamond
William & Mary Annual Tax Conference
No abstract provided.
Civil Penalties Under The Internal Revenue Code, L. Paige Marvel
Civil Penalties Under The Internal Revenue Code, L. Paige Marvel
William & Mary Annual Tax Conference
No abstract provided.
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, Richard E. Levine, David H. Evaul
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, Richard E. Levine, David H. Evaul
William & Mary Annual Tax Conference
No abstract provided.
Interest Expense For Noncorporate Taxpayers After The Tax Reform Act Of 1986, Thomas P. Rohman
Interest Expense For Noncorporate Taxpayers After The Tax Reform Act Of 1986, Thomas P. Rohman
William & Mary Annual Tax Conference
No abstract provided.
Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven
Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven
Faculty Publications
No abstract provided.
The Alternative Minimum Tax For Individuals: Outline, Richard E. Fogg
The Alternative Minimum Tax For Individuals: Outline, Richard E. Fogg
William & Mary Annual Tax Conference
No abstract provided.
Individual Income Taxation After The Tax Reform Act Of 1986, Louis A. Mezzullo
Individual Income Taxation After The Tax Reform Act Of 1986, Louis A. Mezzullo
William & Mary Annual Tax Conference
No abstract provided.
Accounting Methods After The Tax Reform Act Of 1986, Howard J. Busbee
Accounting Methods After The Tax Reform Act Of 1986, Howard J. Busbee
William & Mary Annual Tax Conference
No abstract provided.
Capital Gains Exception To The House's "General Utilities" Repeal: Further Indigestions From Overly Processed "Corn Products", John W. Lee
Faculty Publications
In this article, Lee first describes the mechanics and tax effects of cost basis corporate acquisitions and analyzes why current tax rules favor such acquisitions over carryover basis acquisition (e .g., tax-free mergers); then he describes the House's proposed repeal in HR 3838 of the General Utilities doctrine in current sections 336-338, focusing on the continued exemption for long-term capital gains of a closely held active business corporation. This sets the stage for analysis of the Corn Products doctrine, which under an "integral asset" reading would deny the exemption to most appreciated operating assets, surely not the intent of the …
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Faculty Publications
No abstract provided.
Personal Financial And Tax Planning With Insurance Products And Comparable Investments, William B. Harman Jr.
Personal Financial And Tax Planning With Insurance Products And Comparable Investments, William B. Harman Jr.
William & Mary Annual Tax Conference
No abstract provided.
Individual And Corporate Planning To Avoid Pitfalls Of Minimum Tax, Oliver C. Murray
Individual And Corporate Planning To Avoid Pitfalls Of Minimum Tax, Oliver C. Murray
William & Mary Annual Tax Conference
No abstract provided.
Cash Or Deferred Arrangements (Section 401(K): Legal Issues And Plan Design, William L. Sollee
Cash Or Deferred Arrangements (Section 401(K): Legal Issues And Plan Design, William L. Sollee
William & Mary Annual Tax Conference
No abstract provided.
The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven
The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven
Faculty Publications
No abstract provided.
Planning With The Changed Cost Recovery Rules, Jere D. Mcgaffey
Planning With The Changed Cost Recovery Rules, Jere D. Mcgaffey
William & Mary Annual Tax Conference
No abstract provided.
The Decline And Fall Of Taxable Income, Glenn E. Coven
The Decline And Fall Of Taxable Income, Glenn E. Coven
Faculty Publications
No abstract provided.
The Installment Sales Revision Act Of 1980, Herbert J. Lerner
The Installment Sales Revision Act Of 1980, Herbert J. Lerner
William & Mary Annual Tax Conference
No abstract provided.