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Articles 181 - 210 of 243
Full-Text Articles in Taxation-Federal
A Discussion Of The Application Of Fica And Futa To Indian Tribes' On-Reservation Activities, Robyn L. Robinson
A Discussion Of The Application Of Fica And Futa To Indian Tribes' On-Reservation Activities, Robyn L. Robinson
American Indian Law Review
No abstract provided.
Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch
Taxation Of U.S. Llc With Foreign Participation, Victor Ianovitch
LLM Theses and Essays
The instant thesis is organized in three main parts. The first contains an overview of U.S. law including constitutional issues of the topic focusing on the separation of tax powers between federal and state authorities with special attention to the basis and extent to which a State is entitled to impose levies on business organizations; a brief analysis of federal legislation allowing the pass-through regime; and summary concerning LLC legislation in the States. The second analyzes the application of the main, basic principles of international taxation (such as residence, source rules, application of international treaties, and connected with it the …
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.
The Return Of The White Buffalo: Taxation Issues Facing American Indian Tribes Conducting Gambling Enterprises On Tribal Lands, Jose J. Monsivais
The Return Of The White Buffalo: Taxation Issues Facing American Indian Tribes Conducting Gambling Enterprises On Tribal Lands, Jose J. Monsivais
American Indian Law Review
No abstract provided.
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel S. Goldberg
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel S. Goldberg
Faculty Scholarship
No abstract provided.
And The Rebuttal, Glenn E. Coven
Environmental Accountability Beyond Compliance: Externalities And Accounting, Arthur J. Jacobson
Environmental Accountability Beyond Compliance: Externalities And Accounting, Arthur J. Jacobson
Cardozo Law Review
No abstract provided.
Corporations, Shareholders, And The Environmental Agenda, Nell Minow, Michael Deal
Corporations, Shareholders, And The Environmental Agenda, Nell Minow, Michael Deal
Cardozo Law Review
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.
Good Faith And Chapter 13 Discharge: How Much Discretion Is Too Much?, Ellen M. Horn
Good Faith And Chapter 13 Discharge: How Much Discretion Is Too Much?, Ellen M. Horn
Cardozo Law Review
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.
Recent Approaches To The Trade Or Business Requirement Of Section 174: Unauthorized Snow Removal, Daniel S. Goldberg
Recent Approaches To The Trade Or Business Requirement Of Section 174: Unauthorized Snow Removal, Daniel S. Goldberg
Faculty Scholarship
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.
Taxation Issues Facing The Foreign Athlete Or Entertainer, Debra Dobray, Tim Kreatschman
Taxation Issues Facing The Foreign Athlete Or Entertainer, Debra Dobray, Tim Kreatschman
NYLS Journal of International and Comparative Law
No abstract provided.
Shifting Of Income Within The Family: Will 1986 I.R.C. Changes Bring Significant Reform, John A. Lynch Jr.
Shifting Of Income Within The Family: Will 1986 I.R.C. Changes Bring Significant Reform, John A. Lynch Jr.
All Faculty Scholarship
In challenging Congress and the citizenry to embrace tax reform, President Reagan stated:
While most Americans labor under excessively high tax rates that discourage work and cut drastically into savings, many are able to exploit the tangled mass of loopholes that has grown up around our tax code to avoid paying their fair share-sometimes to avoid paying any taxes at all.
Fairness and simplicity were clearly overriding objectives of the tax reform movement that culminated in the Tax Reform Act of 1986.
From the perspectives of both fairness and simplicity, one of the most egregious features of prior law was …
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.
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
All Faculty Scholarship
As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies the tax treatment of the various types of payments that a partnership may make to a withdrawing partner. It introduced the concept of a liquidation of a partnership interest by the partnership itself, as opposed to the sale of that interest to an outsider or to the continuing partners. In some instances it provides tax consequences for continuing and withdrawing partners which are different from those attendant to a sale. It was designed to make the law concerning disposition of partnership interests simpler and …
For A Few Dollars More: Client’S Right To Discharge His Attorney Under A Contingent Fee Contract, Irving Cohen
For A Few Dollars More: Client’S Right To Discharge His Attorney Under A Contingent Fee Contract, Irving Cohen
Cardozo Law Review
No abstract provided.
Federal Law And State Corporate Income Taxes, Charles E. Mclure, Jr.
Federal Law And State Corporate Income Taxes, Charles E. Mclure, Jr.
Vanderbilt Journal of Transnational Law
Beginning as early as 1959, when the Supreme Court handed down its decision in Northwestern States Portland Cement and Stockham Valves, the business community has repeatedly asked that federal legislation be enacted to restrict the scope of permissible state action in taxing corporate income. In the intervening quarter century, the only federal legislation on state corporate income tax was P.L. 86-272, which restricted the ability of states to tax a nondomiciliary company when the company's only activity in the state was the solicitation of sales. In 1983 following the Court's decision in Container Corporation of America, foreign corporations and foreign …
The Supreme Court's "Resolution" Of The Tax Accrual Workpapers Controversy, Diana Gillett Plotkin
The Supreme Court's "Resolution" Of The Tax Accrual Workpapers Controversy, Diana Gillett Plotkin
Cardozo Law Review
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.
International Tax Evasion: Spawned In The United States And Nurtured By Secrecy Havens, Allaire U. Karzon
International Tax Evasion: Spawned In The United States And Nurtured By Secrecy Havens, Allaire U. Karzon
Vanderbilt Journal of Transnational Law
The United States system of income taxation is predicated upon the voluntary self-assessment and payment of tax. Voluntary compliance, in turn, depends upon the confidence of United States citizens that the taxation system is basically fair, that the tax burden essential to maintain the government is shared by all in proportion to their net income, and that those who cheat are discovered and prosecuted. Circumstances that allow certain taxpayers to escape their proper tax liability successfully tempt others to seek tax evasion devices for themselves, and, more importantly, demoralize the conscientious majority who pay their just share of taxes but …
Comparative Analysis Of Systems Of Domestic Taxation Of Controlled Foreign Corporations, Jamie S. Martin, A. Dale Wilson
Comparative Analysis Of Systems Of Domestic Taxation Of Controlled Foreign Corporations, Jamie S. Martin, A. Dale Wilson
Vanderbilt Journal of Transnational Law
This Note outlines the existing law and practice of the domestic taxation of CFC's in the United States, United Kingdom, France, West Germany, and Japan, each of which exhibits a high level of economic and industrial advancement. United States developments are important because the statutory provisions of Subpart F have been adopted, with modifications, by other nations, including West Germany and Japan. The United Kingdom and France, on the other hand, have not yet adopted an integrated statutory scheme providing for domestic taxation of CFC's. These countries attack tax evasion schemes utilizing foreign controlled companies primarily through general laws, exchange …
The Alternative Minimum Tax: Proving Again That Two Wrongs Do Not Make A Right, Glenn E. Coven
The Alternative Minimum Tax: Proving Again That Two Wrongs Do Not Make A Right, Glenn E. Coven
Faculty Publications
No abstract provided.
Taxation: State Possessory Interest Tax, Patrick E. Powers Jr.
Taxation: State Possessory Interest Tax, Patrick E. Powers Jr.
American Indian Law Review
No abstract provided.