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Articles 2251 - 2280 of 3037
Full-Text Articles in Taxation-Federal
Problem Areas Under Internal Revenue Code Section 704(E): The Family Partnership Revisited, Gerald T. Snow
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.
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.
The Advance Fee Payment Dilemma: Should Payments Be Deposited To The Client Trust Account Or To The General Office Account?, Lester Brickman
The Advance Fee Payment Dilemma: Should Payments Be Deposited To The Client Trust Account Or To The General Office Account?, Lester Brickman
Cardozo Law Review
No abstract provided.
Realization And Recognition Of Losses On Stock Surrenders: A Frolic Through Subchapter C, Gwendolyn Griffith
Realization And Recognition Of Losses On Stock Surrenders: A Frolic Through Subchapter C, Gwendolyn Griffith
Florida State University Law Review
A shareholder's surrender of stock to a corporation for no consideration arguably results in a realized loss to the shareholder. But should that loss be recognized? The Supreme Court's decision in Fink v. Commissioner denied loss recognition for stock surrenders resulting in only a small reduction in a shareholder's percentage ownership in a corporation. While correct in results, the analytical basis for this decision is problematic and offers a unique opportunity to examine the basic issues of loss realization and recognition within the context of subchapter C of the Internal Revenue Code.
Section 752(C): The Other Issue In Tufts V. Commissioner, L. Scott Stafford
Section 752(C): The Other Issue In Tufts V. Commissioner, L. Scott Stafford
Law Faculty Scholarship
No abstract provided.
The Innocent Spouse Provision Under Section 6013(E) Of The Internal Revenue Code: Relief Or Refuse, Michael F. Lax
The Innocent Spouse Provision Under Section 6013(E) Of The Internal Revenue Code: Relief Or Refuse, Michael F. Lax
University of Arkansas at Little Rock Law Review
No abstract provided.
Welcome To The Funhouse: The Incredible Maze Of Modern Divorce Taxation, Beverly I. Moran
Welcome To The Funhouse: The Incredible Maze Of Modern Divorce Taxation, Beverly I. Moran
Vanderbilt Law School Faculty Publications
Using legislative histories the article shows how the incidence of taxation began to fall more heavily on women in the context of divorce as women's social and political status rose during World War II and that this trend continued through several sets of divorce tax reform.
Ird And S Corporations, Gregory V. Gadarian, Jonathan G. Blattmachr
Ird And S Corporations, Gregory V. Gadarian, Jonathan G. Blattmachr
Touro Law Review
No abstract provided.
Who Should Pay The Corporate Tax In A Flat Tax World?, Rebecca S. Rudnick
Who Should Pay The Corporate Tax In A Flat Tax World?, Rebecca S. Rudnick
Articles by Maurer Faculty
This article reviews the corporate tax system within the context of the historical bias and current effects of the current system of taxation of corporations and shareholders. Drawing on public finance theory, financial markets microstructure research, and perspectives on corporate governance, Professor Rudnick proposes a profits tax on the liquid equity of firms. She finds this to be a normative rationale for a double tax system under optimal tax principles due to the inelasticity of demand for and supply of liquidity and the economic rent it produces. The value of liquidity in different capital markets is the crucial determinate. Under …
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.
Tax Avoidance And Income Measurement, Joshua D. Rosenberg
Tax Avoidance And Income Measurement, Joshua D. Rosenberg
Michigan Law Review
This article first will explain our system of "transaction taxation" and will further explore the problems caused by the transactional focus of our tax system. It then will consider the current judicial responses to these problems and examine their inadequacies. Finally, it will set forth and explore the alternative responses suggested above in more detail.
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
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.
Class Tax To Mass Tax: The Role Of Propaganda In The Expansion Of The Income Tax During World War Ii, Carolyn C. Jones
Class Tax To Mass Tax: The Role Of Propaganda In The Expansion Of The Income Tax During World War Ii, Carolyn C. Jones
Buffalo Law Review
No abstract provided.
What Has Happened To The Tax Legislative Process?, Pamela Brooks Gann
What Has Happened To The Tax Legislative Process?, Pamela Brooks Gann
Michigan Law Review
A Review of Showdown at Gucci Gulch: Lawmakers, Lobbyists and the Unlikely Triumph of Tax Reform by Jeffrey H. Birnbaum and Alan S. Murray
Improving The Earned Income Credit: Transition To A Wage Subsidy Credit For The Working Poor, Jonathan Barry Forman
Improving The Earned Income Credit: Transition To A Wage Subsidy Credit For The Working Poor, Jonathan Barry Forman
Florida State University Law Review
Millions of American families have incomes that fall below the poverty line. Of these, many families are poor despite the fact that at least one member of these families works during the year. In this article, Professor Forman examines one tool in the fight against poverty, the earned income credit. Professor Forman examines the history of the credit and its shortcoming and then suggests ways in which the credit could be improved to better serve the working poor.
Federal Income Tax—Exceptions To Definition Of Capital Asset Are Narrowed. Arkansas Best Corp. V. Commissioner, 108 S. Ct. 971 (1988)., Mike Watts
University of Arkansas at Little Rock Law Review
No abstract provided.
The Taxation Of Prizes And Awards—Tax Policy Winners And Losers, Bruce I. Kogan
The Taxation Of Prizes And Awards—Tax Policy Winners And Losers, Bruce I. Kogan
Washington Law Review
This article evaluates whether the recent emasculation of the exclusion for bona fide public achievement prizes or awards was justified. In order to accomplish the task, the article will begin by setting forth the applicable statutory provisions and tracing their historical development. Second, the policy implications of new section 74(b) will be analyzed in depth. Next, the article will offer an alternative that would effectively deal with the problem of compensatory employer to employee awards, while retaining the long standing policy of using tax incentives to encourage humanitarian or public contribution. The article concludes by arguing that Congress' shift to …
The Taxation Of Prizes And Awards—Tax Policy Winners And Losers, Bruce I. Kogan
The Taxation Of Prizes And Awards—Tax Policy Winners And Losers, Bruce I. Kogan
Washington Law Review
This article evaluates whether the recent emasculation of the exclusion for bona fide public achievement prizes or awards was justified. In order to accomplish the task, the article will begin by setting forth the applicable statutory provisions and tracing their historical development. Second, the policy implications of new section 74(b) will be analyzed in depth. Next, the article will offer an alternative that would effectively deal with the problem of compensatory employer to employee awards, while retaining the long standing policy of using tax incentives to encourage humanitarian or public contribution. The article concludes by arguing that Congress' shift to …
Tax Symposium: An Overview Of The Low Income Housing Tax Credit, Andrew Zack Blatter, Elena Marty-Nelson
Tax Symposium: An Overview Of The Low Income Housing Tax Credit, Andrew Zack Blatter, Elena Marty-Nelson
University of Baltimore Law Review
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.
The Alternative Minimum Tax For Individuals: Present Problems And Future Possibilities, Kerry Sean Bucklin
The Alternative Minimum Tax For Individuals: Present Problems And Future Possibilities, Kerry Sean Bucklin
Washington Law Review
This Comment addresses the problems presented by the revised alternative tax. First, the alternative tax is described in the context of the 1986 Tax Reform Act. Second, the new provisions of the alternative tax are analyzed to show that even with them, the alternative tax still does not tax all economic income. Third, the inefficiency and inequitable nature of the alternative tax are examined. Fourth, short and long-term solutions to the current alternative tax problems are proposed.
The Canadian White Paper On Sales Tax Reform And The Model Value Added Tax Statute For The United States: A Comparative Analysis, Alan Schenk
Law Faculty Research Publications
No abstract provided.
Tax Symposium: Capital Losses: Falling Short On Fairness And Simplicity, Fred W. Peel Jr.
Tax Symposium: Capital Losses: Falling Short On Fairness And Simplicity, Fred W. Peel Jr.
University of Baltimore Law Review
No abstract provided.
The Alternataive Minimum Tax For Individuals: Present Problems And Future Possibilities, Kerry Sean Bucklin
The Alternataive Minimum Tax For Individuals: Present Problems And Future Possibilities, Kerry Sean Bucklin
Washington Law Review
This Comment addresses the problems presented by the revised alternative tax. First, the alternative tax is described in the context of the 1986 Tax Reform Act. Second, the new provisions of the alternative tax are analyzed to show that even with them, the alternative tax still does not tax all economic income. Third, the inefficiency and inequitable nature of the alternative tax are examined. Fourth, short and long-term solutions to the current alternative tax problems are proposed.
University Of Richmond Law Review
University Of Richmond Law Review
University of Richmond Law Review
No abstract provided.
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Articles
The General Utilities doctrine is the name given to the now largely defunct tax rule that a corporation does not recognize a gain or a loss on making a liquidating or nonliquidating distribution of an appreciated or depreciated asset to its shareholders. The roots of the doctrine, can be traced to a regulation promulgated in 1919 that denied realization of gain or loss to a corporation when making a liquidating distribution of an asset in kind. No regulatory provision existed which specified the extent to which realization would or would not be triggered by a nonliquidating distribution such as a …
Tax Collection And Populist Rhetoric: Shifting The Burden Of Proof In Tax Cases, Leo P. Martinez
Tax Collection And Populist Rhetoric: Shifting The Burden Of Proof In Tax Cases, Leo P. Martinez
Faculty Scholarship
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.