Proposal For A Non-Subsidized, Non-Retirement-Plan, Employee-Owned Investment Vehicle To Replace The Esop,
2018
University of Illinois College of Law
Proposal For A Non-Subsidized, Non-Retirement-Plan, Employee-Owned Investment Vehicle To Replace The Esop, Sean M. Anderson, Andrew Stumpff Morrison
Law & Economics Working Papers
The authors have previously been critical of the existing American legal exemption and subsidy regime for employee stock ownership plans (“ESOPs”). By definition such plans create dangerously undiversified investment programs tying employees’ retirement security to the financial health of a single company – which, to compound the problem, is the employees’ employer, thereby correlating participants’ retirement security risk with the risk of losing their jobs. No demonstrated compensating policy benefit justifies this extraordinary large-scale departure from basic principles of financial prudence. One context, however, where a plausible case might be made for employee ownership is that which arises when a …
Analysis Of H.R.2802 - 115th Congress (2017-2018) First-Time Homebuyer Savings Account Act Of 2017,
2018
San Jose State University
Analysis Of H.R.2802 - 115th Congress (2017-2018) First-Time Homebuyer Savings Account Act Of 2017, Shimiao Gong, Xiaotong Stella Li, Ling Wei, Pingrong Xue
The Contemporary Tax Journal
No abstract provided.
Why Section 179(B)(3)(A)'S Business Income Limitation Does Not Apply To Partnerships And S Corporations,
2018
San Jose State University
Why Section 179(B)(3)(A)'S Business Income Limitation Does Not Apply To Partnerships And S Corporations, David Randall Jenkins Ph.D.
The Contemporary Tax Journal
No abstract provided.
Who Truly Benefits From The Mortgage Interest Deduction?,
2018
San Jose State University
Who Truly Benefits From The Mortgage Interest Deduction?, Stephen Wildt Mba
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal's Interview With Mr. Jim Fuller,
2018
San Jose State University
The Contemporary Tax Journal's Interview With Mr. Jim Fuller, Ophelia Ding
The Contemporary Tax Journal
No abstract provided.
Analysis Of S.1352 - 115th Congress (2017-2018) Apprenticeship And Jobs Training Act Of 2017,
2018
San Jose State University
Analysis Of S.1352 - 115th Congress (2017-2018) Apprenticeship And Jobs Training Act Of 2017, Veena Hemachandran, Katrina Jodrey, George (Peixuan) Liu, Leigh Ann Moore
The Contemporary Tax Journal
No abstract provided.
Latent Semantic Analysis: A Big Data Opportunity For Tax Research,
2018
University of North Texas
Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., Cpa, Benjamin George Ph.D.
The Contemporary Tax Journal
No abstract provided.
Tax Treatment Of High-Tech Start-Up Costs,
2018
San Jose State University
Tax Treatment Of High-Tech Start-Up Costs, June (Yun) Hostetter Cpa
The Contemporary Tax Journal
No abstract provided.
R&D Credit Against Payroll Tax Liabilities - The Payroll Tax Credit,
2018
San Jose State University
R&D Credit Against Payroll Tax Liabilities - The Payroll Tax Credit, Sarah Yaqin Sun
The Contemporary Tax Journal
No abstract provided.
Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act,
2018
San Jose State University
Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018,
2018
San Jose State University
The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018
The Contemporary Tax Journal
No abstract provided.
Is American Multinational Enterprises’ Honeymoon With The European Union Over?An Analysis Of The European Commission’S Investigations Into American Multinational Enterprises’ Tax Deals With Ireland, Luxembourg And The Netherlands,
2018
Loyola Law School, Los Angeles
Is American Multinational Enterprises’ Honeymoon With The European Union Over?An Analysis Of The European Commission’S Investigations Into American Multinational Enterprises’ Tax Deals With Ireland, Luxembourg And The Netherlands, Luyang Liu
Loyola of Los Angeles International and Comparative Law Review
No abstract provided.
Summaries For The 2017 Irs-Sjsu Small Business Tax Institute,
2018
San Jose State University
Summaries For The 2017 Irs-Sjsu Small Business Tax Institute, Ruchi Chopra Cpa, Mba, Ophelia Ding, Surbhi Doshi, Nilesh Lad Cpa, Sara Yaqin Sun
The Contemporary Tax Journal
No abstract provided.
The Elephant Always Forgets: Us Tax Reform And The Wto,
2018
University of Michigan Law School
The Elephant Always Forgets: Us Tax Reform And The Wto, Reuven S. Avi-Yonah, Martin G. Vallespinos
Law & Economics Working Papers
The “Tax Cuts and Jobs Act” (TCJA) enacted on December 22, 2017 includes several provisions that raise WTO compliance issues. At least one such provision, the Foreign-Derived Intangible Income (FDII) rule, is almost certain to draw a challenge in the WTO and is likely to lead to another US loss and resulting sanctions. This outcome would be another addition to the repeated losses suffered by the US for export subsidies from the 1970s to 2004, which led to the imposition of sanctions and the ultimate repeal of the offending regime. The important question for 2018 and beyond is whether the …
Loudoun County, Virginia V. Dulles Duty Free, Llc: Brief Of Tax Law Professors As Amici Curiae In Support Of Petitioner,
2018
Unviersity of Michigan Law School
Loudoun County, Virginia V. Dulles Duty Free, Llc: Brief Of Tax Law Professors As Amici Curiae In Support Of Petitioner, Reuven S. Avi-Yonah
Appellate Briefs
Amici are professors of tax law at universities across the United States. As scholars and teachers, they have considered the doctrinal roots and practical consequences of judicial limits on state and local taxation. Amici join this brief solely on their own behalf and not as representatives of their universities. A full list of amici appears in the Appendix to this brief.
For more than seven decades, state and local governments as well as market actors have labored under an export tax regime that is inconsistent, inefficient, and inequitable. This case presents the Court with a chance to restore rationality to …
Brief Of Tax Law Professors As Amici Curiae In Support Of Petitioner,
2018
Benjamin N. Cardozo School of Law
Brief Of Tax Law Professors As Amici Curiae In Support Of Petitioner, Edward A. Zelinsky
Amicus Briefs
Amici are professors of tax law at universities across the United States. As scholars and teachers, they have considered the doctrinal roots and practical consequences of judicial limits on state and local taxation. Amici join this brief solely on their own behalf and not as representatives of their universities. A full list of amici appears in the Appendix to this brief.
A Vatcoin Solution To Mtic Fraud: Past Efforts, Present Technology, And The Eu’S 2017 Proposal,
2018
Boston University School of Law
A Vatcoin Solution To Mtic Fraud: Past Efforts, Present Technology, And The Eu’S 2017 Proposal, Richard Thompson Ainsworth, Musaad Alwohaibi, Mike Cheetham, Camille Tirand
Faculty Scholarship
On October 4, 2017, in an effort to recover some of the VAT lost annually, the European Commission proposed “far-reaching reforms.” The immediate target is a €50 billion slice of an estimated €150 billion overall annual loss. In its proposal the Commission is looking only at Missing Trader Intra-Community (MTIC) fraud in goods.
Goods (alone) are targeted. If we have learned anything about MTIC fraud since January 1, 1993, it is that fraudsters engaged in this activity are exceptionally agile. MTIC frauds migrate and mutate on command. For example, MTIC fraud in cell phones quickly migrated to computer chips in …
Prop Up The Heavenly Chorus? Labor Unions, Tax Policy, And Political Voice Equality,
2018
St. John's University School of Law
Prop Up The Heavenly Chorus? Labor Unions, Tax Policy, And Political Voice Equality, Philip T. Hackney
St. John's Law Review
(Excerpt)
This Article contributes to the tax legal literature by providing an analysis of labor unions and how we tax them. Although labor unions as a whole are a very small part of our economy and tax system, by looking at one narrow section of the tax-exempt sector we can shed light on the rest of the exempt sector. Additionally, although most tax policy scholarship focuses on one of three values—equity in an economic sense, efficiency in an economic sense, and administrability—I focus primarily on the value of equity in a governance sense.
I argue that, at least in the …
Cracking Shells: The Panama Papers & Looking To The European Union's Anti-Money Laundering Directive As A Framework For Implementing A Multilateral Agreement To Combat The Harmful Effects Of Shell Companies,
2018
Texas A&M University School of Law
Cracking Shells: The Panama Papers & Looking To The European Union's Anti-Money Laundering Directive As A Framework For Implementing A Multilateral Agreement To Combat The Harmful Effects Of Shell Companies, Nicholas Vail
Texas A&M Law Review
In early 2016, the International Consortium of Investigative Journalists released a report detailing thousands of leaked documents demonstrating how a Panamanian law firm had, for years, helped wealthy clients conceal their financial activities through the use of offshore shell companies. The Panama Papers, as the leaked documents came to be known, directed renewed attention at the use of shell companies. Shell companies are used by the world’s wealthy and powerful to lower their taxes, but are also used by tax evaders, criminal organizations, and terrorists. While much of the renewed attention has been directed at offshore tax havens such as …
Beat It: Tax Reform And Tax Treaties,
2018
University of Michigan Law School
Beat It: Tax Reform And Tax Treaties, Reuven S. Avi-Yonah
Law & Economics Working Papers
The Tax Cuts and Jobs Act (TCJA) includes several provisions that may be viewed as potential violations of US tax treaties. However, most of those potential violations, such as new IRC section 951A and to a large extent new IRC section 59A, are covered by the Savings Clause (US model article 1(4)). The only remaining question is whether IRC section 59A (the “Base Erosion Anti-Abuse Tax”, or BEAT) violates the non-discrimination provision (article 24), which is exempted from the Savings Clause. The answer is no, because foreign related parties are not comparable to US related parties receiving interest or royalties.
