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Articles 1 - 30 of 38
Full-Text Articles in Taxation-Federal
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.
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.
Fewer Tax Returns, Alan L. Feld
Fewer Tax Returns, Alan L. Feld
Faculty Scholarship
Professor Alan L. Feld presents a proposal for simplifying the income tax by reducing the number of taxpayers who have to file returns.
Recent Federal Income Tax Developments, Ira B. Shepard
Recent Federal Income Tax Developments, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Nonqualified Deferred Compensation Plans And Equity-Based Compensation, Louis A. Mezzullo
Nonqualified Deferred Compensation Plans And Equity-Based Compensation, Louis A. Mezzullo
William & Mary Annual Tax Conference
No abstract provided.
Executive Compensation: Dealing With The New Law And Other Developments, William Dunn
Executive Compensation: Dealing With The New Law And Other Developments, William Dunn
William & Mary Annual Tax Conference
No abstract provided.
Theories Of The Federal Income Tax Exemption For Charities: Thesis, Anithesis, And Synthesis, Rob Atkinson
Theories Of The Federal Income Tax Exemption For Charities: Thesis, Anithesis, And Synthesis, Rob Atkinson
Scholarly Publications
No abstract provided.
Sierra Club V. Commissioner And The Royalty Exemption To The Unrelated Business Income Tax: How Much Activity Is Too Much?, Katherine A. Vanye
Sierra Club V. Commissioner And The Royalty Exemption To The Unrelated Business Income Tax: How Much Activity Is Too Much?, Katherine A. Vanye
Washington Law Review
In Sierra Club v. Commissioner, the Ninth Circuit decided that royalties are payments for the right to use intangible property and are by definition "passive." The court applied this definition and held that Sierra Club's income from renting its mailing list was a royalty payment and thus exempt from taxation. This Note argues that while the court reached the correct conclusion, it did not propose a clear standard to guide future cases. Two alternative approaches could be adopted: (1) ancillary versus significant services; or (2) comparative value of property and services. These alternatives will provide clearer guidelines and enable …
The Deemed Transfer Of Recourse Liabilities Leads To Owen Taxes: What Is Wrong With Form Over Substance?, Christine L. Agnew
The Deemed Transfer Of Recourse Liabilities Leads To Owen Taxes: What Is Wrong With Form Over Substance?, Christine L. Agnew
University of Miami Law Review
No abstract provided.
The Essays Of Warren Buffett: Lessons For Corporate America, Lawrence A. Cunningham
The Essays Of Warren Buffett: Lessons For Corporate America, Lawrence A. Cunningham
Cardozo Law Review
No abstract provided.
The Human Corporation: Some Thoughts On Hume, Smith, And Buffett, Lawrence E. Mitchell
The Human Corporation: Some Thoughts On Hume, Smith, And Buffett, Lawrence E. Mitchell
Cardozo Law Review
No abstract provided.
Introduction To The Warren Buffett Symposium Papers, Lawrence A. Cunningham
Introduction To The Warren Buffett Symposium Papers, Lawrence A. Cunningham
Cardozo Law Review
No abstract provided.
Accounting In Favor Of Investors, Calvin H. Johnson
Accounting In Favor Of Investors, Calvin H. Johnson
Cardozo Law Review
No abstract provided.
Teaching Accounting And Valuation In The Basic Corporation Law Course, Elliott J. Weiss
Teaching Accounting And Valuation In The Basic Corporation Law Course, Elliott J. Weiss
Cardozo Law Review
No abstract provided.
Buffett, Corporate Objectives, And The Nature Of Sheep, Henry T.C. Hu
Buffett, Corporate Objectives, And The Nature Of Sheep, Henry T.C. Hu
Cardozo Law Review
No abstract provided.
Warren E. Buffett On Corporate Constituency Laws And Other Newfangled Ideas: An Imaginary Conversation, Bevis Longstreth
Warren E. Buffett On Corporate Constituency Laws And Other Newfangled Ideas: An Imaginary Conversation, Bevis Longstreth
Cardozo Law Review
No abstract provided.
Berkshire Hathaway's Uncommon Accounting, Edmund W. Kitch
Berkshire Hathaway's Uncommon Accounting, Edmund W. Kitch
Cardozo Law Review
No abstract provided.
Selected International Aspects Of Fundamental Tax Reform Proposals, Stephen E. Shay, Victoria P. Summers
Selected International Aspects Of Fundamental Tax Reform Proposals, Stephen E. Shay, Victoria P. Summers
University of Miami Law Review
No abstract provided.
International Aspects Of Fundamental Tax Restructuring: Practice Or Principle?, Michael J. Graetz
International Aspects Of Fundamental Tax Restructuring: Practice Or Principle?, Michael J. Graetz
University of Miami Law Review
No abstract provided.
Comment: What's On Second?, George Mundstock
Comment: What's On Second?, George Mundstock
University of Miami Law Review
No abstract provided.
Kochanksky V. Commissioner: The Assignment Of Income Doctrine, Community Property Law, And I.R.C. § 1041, Sarah Dods
Kochanksky V. Commissioner: The Assignment Of Income Doctrine, Community Property Law, And I.R.C. § 1041, Sarah Dods
Washington Law Review
In Kochansky v. Commissioner, the Ninth Circuit held that an attorney was fully taxable on a contingent fee he agreed to split with his spouse at divorce, reasoning that the assignment of income doctrine requires that income be taxed to the person who earns it. This Note observes that in applying the assignment doctrine, the Kochansky court erred by failing to determine the extent of the spouse's community property interest in the contingent fee; community property income must be taxed one-half to each spouse, regardless of which spouse earns it, which spouse collects it, and when it is collected. …
Comments On Professor Peroni's Paper On Reform Of The U.S. International Income Tax Rules, David R. Tillinghast
Comments On Professor Peroni's Paper On Reform Of The U.S. International Income Tax Rules, David R. Tillinghast
University of Miami Law Review
No abstract provided.
Federal Taxation, Ben E. Muraskin, James A. Lawton, Tiffani W. Greene
Federal Taxation, Ben E. Muraskin, James A. Lawton, Tiffani W. Greene
Mercer Law Review
No abstract provided.
Back To The Future: A Path To Progressive Reform Of The U.S. International Income Tax Rules, Robert J. Peroni
Back To The Future: A Path To Progressive Reform Of The U.S. International Income Tax Rules, Robert J. Peroni
University of Miami Law Review
No abstract provided.
The Future Of Capital Export Neutrality: A Comment On Robert Peroni's Path To Progressive Reform Of The U.S. International Tax Rules, Stanley I. Langbein
The Future Of Capital Export Neutrality: A Comment On Robert Peroni's Path To Progressive Reform Of The U.S. International Tax Rules, Stanley I. Langbein
University of Miami Law Review
No abstract provided.
Comment On Shay And Summers: Selected International Aspects Of Fundamental Tax Reform Proposals, Reuven S. Avi-Yonah
Comment On Shay And Summers: Selected International Aspects Of Fundamental Tax Reform Proposals, Reuven S. Avi-Yonah
University of Miami Law Review
No abstract provided.
The Definition Of Voting Stock And The Computation Of Voting Power Under Sections 368(C) And 1504(A): Recent Developments And Tax Lore, Stuart G. Lazar
The Definition Of Voting Stock And The Computation Of Voting Power Under Sections 368(C) And 1504(A): Recent Developments And Tax Lore, Stuart G. Lazar
Journal Articles
Although the concepts of "voting stock" and "voting power" are pervasive throughout the Code, until recently, courts, commentators and the Service have devoted minimal energy to demystifying the confusion surrounding the definition of voting stock and even less to expanding upon the methodology of computing voting power. Recent developments, however, may prompt practitioners to take a second look at these terms. While a 1995 decision by the Tax Court adds little to the existing body of authority with respect to the determination of the owner of voting stock, the Service's analysis of the voting power requirement in a 1994 private …
Distributions From Qualified Plans And Ira' S, Oregon Law Institute, Everett R. Moreland, Bruce J. Temkin, Deborah L. Thomas
Distributions From Qualified Plans And Ira' S, Oregon Law Institute, Everett R. Moreland, Bruce J. Temkin, Deborah L. Thomas
Oregon Law Institute, 1997
Course Materials from the June 13, 1997 Program in Portland
1997 Business Law Institute: Advising Your Business Client, Oregon Law Institute, Robert K. Winger, Steven C. Alberty, Nancy J. Brown, Sylvia E. Stevens, Andrea Bartoloni, Tifani M. Parrilli, James L. Knoll, Beth R. Skillern, Linda M. Bolduan, Gary W. Glisson, David P. Peterson
1997 Business Law Institute: Advising Your Business Client, Oregon Law Institute, Robert K. Winger, Steven C. Alberty, Nancy J. Brown, Sylvia E. Stevens, Andrea Bartoloni, Tifani M. Parrilli, James L. Knoll, Beth R. Skillern, Linda M. Bolduan, Gary W. Glisson, David P. Peterson
Oregon Law Institute, 1997
Course Materials from the May 2, 1997 Program in Portland
The Hidden Costs Of The Progressivity Debate, Nancy C. Staudt
The Hidden Costs Of The Progressivity Debate, Nancy C. Staudt
Vanderbilt Law Review
Progressive taxation-taxing high income individuals at a proportionally higher level than low income individuals-has sparked more than a century of controversy. Those who support progressive taxation have heralded it as a policy that promotes the greatest good for the greatest number in society protects traditional democratic values, reflects the communitarian world-view of women who see themselves as responsible for the well-being of all individuals, and reveals the "aesthetic judgment" that income inequality is "distinctly evil or unlovely." At the same time, critics have condemned progressive income taxation as social policy that amounts to theft and involuntary servitude, reflects the democratic …
Government Precommitment To Tax Incentive Subsidies: The Impact Of United States V. Winstar Corp. On Retroactive Tax Legislation, Daniel S. Goldberg
Government Precommitment To Tax Incentive Subsidies: The Impact Of United States V. Winstar Corp. On Retroactive Tax Legislation, Daniel S. Goldberg
Faculty Scholarship
No abstract provided.