When Are You An Investor Versus A Dealer In Real Property? (Powerpoint),
2018
William & Mary Law School
When Are You An Investor Versus A Dealer In Real Property? (Powerpoint), James B. Sowell, Stephen J. Giordano
William & Mary Annual Tax Conference
No abstract provided.
At A Loss: Excess Business Loss And Nol Provisions Of The Tcja (Powerpoint),
2018
William & Mary Law School
At A Loss: Excess Business Loss And Nol Provisions Of The Tcja (Powerpoint), Brian J. O'Connor, Stephen M. Sharkey
William & Mary Annual Tax Conference
No abstract provided.
Advising Partners And Partnerships Under The New Centralized Partnership Audit Rules: The Need To Amend Partnership And Llc Operating Agreements (Powerpoint),
2018
William & Mary Law School
Advising Partners And Partnerships Under The New Centralized Partnership Audit Rules: The Need To Amend Partnership And Llc Operating Agreements (Powerpoint), Jerald D. August
William & Mary Annual Tax Conference
No abstract provided.
Recent Developments In Virginia Taxation,
2018
William & Mary Law School
Recent Developments In Virginia Taxation, Craig D. Bell
William & Mary Annual Tax Conference
No abstract provided.
International Provisions Of Public Law No. 115-97 (The “Tcja”) (Powerpoint),
2018
William & Mary Law School
International Provisions Of Public Law No. 115-97 (The “Tcja”) (Powerpoint), William B. Sherman
William & Mary Annual Tax Conference
No abstract provided.
Nonqualified Employee Benefits For Privately-Held Companies – Equity And Deferred Compensation Opportunities (Outline),
2018
William & Mary Law School
Nonqualified Employee Benefits For Privately-Held Companies – Equity And Deferred Compensation Opportunities (Outline), Taylor W. French, G. William Tysse
William & Mary Annual Tax Conference
No abstract provided.
Applying The New 20% Passthroughs Deduction Under Section 199a In The Real World (Powerpoint),
2018
William & Mary Law School
Applying The New 20% Passthroughs Deduction Under Section 199a In The Real World (Powerpoint), James B. Sowell, Stephen J. Giordano, Mark C. Van Deusen
William & Mary Annual Tax Conference
No abstract provided.
Mergers And Acquisitions Of Closely-Held Corporations (Outline),
2018
William & Mary Law School
Mergers And Acquisitions Of Closely-Held Corporations (Outline), Jerald D. August
William & Mary Annual Tax Conference
No abstract provided.
An Overview Of Partnerships (Powerpoint),
2018
William & Mary Law School
An Overview Of Partnerships (Powerpoint), Ari Berk, Drew Tidwell
William & Mary Annual Tax Conference
No abstract provided.
Getting Their Fix: Doctor's Dependency On Big Pharma,
2018
University of Missouri School of Law
Getting Their Fix: Doctor's Dependency On Big Pharma, Larissa Tiller
The Business, Entrepreneurship & Tax Law Review
Section 6002 of the Affordable Care Act, also known as the “Sunshine Act,” was intended to stop corrupt practices within the medical community by requiring pharmaceutical and medical device manufacturers to disclose all transfers of value of a certain amount made between them and physicians. This article suggests that the better solution to stopping corrupt practices is to ban some transfers all together.
2018 Tax Conference Speakers,
2018
William & Mary Law School
2018 Tax Conference Speakers
William & Mary Annual Tax Conference
No abstract provided.
2018 Tax Conference Forms,
2018
William & Mary Law School
Corporate And Business Law,
2018
University of Richmond
Corporate And Business Law, Christopher L. Mclean
University of Richmond Law Review
The past two years have produced a number of pieces of legislation from the Virginia General Assembly that serve to bring the set of Virginia business entity statutes up to date with its peers around the country. Part I highlights changes to the Virginia Stock Corporation Act (“VSCA”) and the Virginia Nonstock Corporation Act (“VNSCA”). Part II highlights changes to the Virginia Securities Act (“VSA”) and other statutes affecting Virginia business entities. Part III reviews two significant cases that the Supreme Court of Virginia decided over the past two years with respect to Virginia corporate law. Those decisions provided guidance …
Taxation,
2018
University of Richmond
Taxation, Craig G. Bell, Michael H. Brady
University of Richmond Law Review
This article reviews significant recent developments in the laws affecting Virginia state and local taxation. Its sections cover legislative activity, judicial decisions, and selected opinions or pronouncements from the Virginia Department of Taxation and the Attorney General of Virginia over the past year.
2018 Schedule,
2018
William & Mary Law School
International Taxation In An Era Of Digital Disruption: Analyzing The Current Debate,
2018
Georgetown University Law Center
International Taxation In An Era Of Digital Disruption: Analyzing The Current Debate, Itai Grinberg
Georgetown Law Faculty Publications and Other Works
The “taxation of the digital economy” is currently at the top of the global international tax policymaking agenda. A core claim some European governments are advancing is that user data or user participation in the digital economy justifies a gross tax on digital receipts, new profit attribution criteria, or a special formulary apportionment factor in a future formulary regime targeted specifically at the “digital economy.” Just a couple years ago the OECD undertook an evaluation of whether the digital economy can (or should) be “ring-fenced” as part of the BEPS project, and concluded that it neither can be nor should …
The Digital Services Tax: A Conceptual Defense,
2018
Allard School of Law at the University of British Columbia
The Digital Services Tax: A Conceptual Defense, Wei Cui
All Faculty Publications
As 2018 nears its end, a digital service tax (DST) seems imminent in Europe, yet elaborations of the DST’s motivations have so far come primarily from the European Commission and the UK Treasury: academic and practitioner commentators remain largely skeptical. This paper offers a new conceptual defense of the DST that is independent of the existing government positions. I argue that a clear case can be made for the DST as a way of taxing location-specific rent earned by digital platforms. While the DST may also be partially motivated by other, potentially conflicting visions for reforming international taxation, such as …
Tax Treaty Abuse And The Principal Purpose Test - Part I,
2018
Allard School of Law at the University of British Columbia
Tax Treaty Abuse And The Principal Purpose Test - Part I, David G. Duff
All Faculty Publications
The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) has been described as “an historical turning point in the area of international taxation” which introduces a third layer of tax rules for the taxation of cross-border transactions in addition to domestic tax law and bilateral tax treaties. Of the many provisions of the MLI, the most important are the preamble text in Article 6(1) and the so-called principal purpose test (PPT) in Article 7(1), both of which have been adopted by all signatories to the MLI in order to satisfy the OECD’s minimum …
Tax Treaty Abuse And The Principal Purpose Test: Part Ii,
2018
Allard School of Law at the University of British Columbia
Tax Treaty Abuse And The Principal Purpose Test: Part Ii, David G. Duff
All Faculty Publications
The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting or Multilateral Instrument (MLI) has been described as “an historical turning point in the area of international taxation” which introduces a third layer of tax rules for the taxation of cross-border transactions in addition to domestic tax law and bilateral tax treaties. Of the many provisions of the MLI, the most important are the preamble text in Article 6(1) and the so-called principal purpose test (PPT) in Article 7(1), both of which have been adopted by all signatories to the MLI in order to satisfy …
Legislative Foundation Of The United States' New International Tax System,
2018
Seattle University School of Law
Legislative Foundation Of The United States' New International Tax System, Joshua D. Harms
Seattle University Law Review
This Note begins with commentary on the United States’ former worldwide system of taxation. This system taxed multinational corporations’ offshore profits at the applicable domestic income tax rate less credits for taxes paid to foreign governments. This tax regime provided for the deferral of income tax due on the profits of multinational corporations’ overseas operations until the time of repatriation. This Note considers the issues inherent in this system and analyzes the repatriation tax holiday under the American Jobs Creation Act of 2004. This holiday has been unanimously criticized by both sides of the political aisle and led to large …
