The 40th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov. 4-5, 2024: R&D In Uncertain Tax Times,
2024
San Jose State Univerity
The 40th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov. 4-5, 2024: R&D In Uncertain Tax Times, Jing Luo
The Contemporary Tax Journal
No abstract provided.
The 40th Tei-Sjsu High Tech Tax Institute Conference On Nov 4-5, 2024: Ip Development In Other Countries,
2024
San Jose State University
The 40th Tei-Sjsu High Tech Tax Institute Conference On Nov 4-5, 2024: Ip Development In Other Countries, Junli Zhang
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview With Benjamin R. Shreck,
2024
San Jose State Univerity
The Contemporary Tax Journal’S Interview With Benjamin R. Shreck, Shuang Zhang
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.),
2024
San Jose State University
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
Analysis Of H.R. 7458 - 118th Congress Made In The U.S.A. Act.,
2024
San Jose State Univerity
Analysis Of H.R. 7458 - 118th Congress Made In The U.S.A. Act., Jung-Hee Kwon, Jinjin Yang
The Contemporary Tax Journal
No abstract provided.
Gleim Cpa Review — Regulation (Reg) & Tax Compliance And Planning (Tcp) Sample Questions,
2024
San Jose State University
Gleim Cpa Review — Regulation (Reg) & Tax Compliance And Planning (Tcp) Sample Questions
The Contemporary Tax Journal
No abstract provided.
Fbar Penalty Is Not Extinguished At Death: Hendler, No. 23 Civ. 3280 (Deh) (Sd Ny, 2024),
2024
San Jose State Univerity
Fbar Penalty Is Not Extinguished At Death: Hendler, No. 23 Civ. 3280 (Deh) (Sd Ny, 2024), Shuang Zhang
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 13, No. 2 – Winter 2024,
2024
San Jose State University
The Contemporary Tax Journal Volume 13, No. 2 – Winter 2024
The Contemporary Tax Journal
No abstract provided.
The 40th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov. 4-5, 2024: Ai In The Corporate Tax Department - Let’S See It!,
2024
San Jose State Univerity
The 40th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov. 4-5, 2024: Ai In The Corporate Tax Department - Let’S See It!, Raymond Clark
The Contemporary Tax Journal
No abstract provided.
The 40th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov 4-5, 2024: The Future Of The Corporate Tax Department,
2024
San Jose State Univerity
The 40th Annual Tei-Sjsu High Tech Tax Institute Conference On Nov 4-5, 2024: The Future Of The Corporate Tax Department, Cynthia Flores
The Contemporary Tax Journal
No abstract provided.
Deductibility Of Investigatory Expenses Incurred In Business Expansion: North Carolina National Bank V. United States,
2024
University of Maine School of Law
Deductibility Of Investigatory Expenses Incurred In Business Expansion: North Carolina National Bank V. United States, Edward R. Benjamin Jr.
Maine Law Review
Section 162 of the Internal Revenue Code allows the current deduction of "all the ordinary and necessary expenses paid or incurred . . . in carrying on any trade or business . . . .” Exactly which business expenditures meet the requirements of section 162, however, has not been easy for courts to determine. In an attempt to enunciate a standard that is easily applicable to complex business transactions, courts have refused to allow current deduction of business expenditures which result in a benefit or advantage with a useful life which continues beyond the taxable year. In North Carolina National …
Application Of The Federal Securities Acts To The Sale Of A Closely Held Corporation By Stock Transfer,
2024
University of Maine School of Law
Application Of The Federal Securities Acts To The Sale Of A Closely Held Corporation By Stock Transfer, Loftus C. Carson Ii
Maine Law Review
The purchase and sale of a closely held corporation is a commonly occurring transaction which may be accomplished by a transfer of stock or a transfer of assets. Structuring such a transaction as a sale of stock, however, may offer certain advantages not attainable if the transaction is structured as a sale of assets. For example, non-assignable contracts and leases, not transferable with a sale of assets, may pass to the transferee of corporate stock. The transferor generally will be absolved of all of the enterprise's liabilities since, by law, they pass with the transfer. Transferors subject to compliance with …
Backing-Into Internal Revenue Code Section 338,
2024
University of Maine School of Law
Backing-Into Internal Revenue Code Section 338, Drew Erik Swenson
Maine Law Review
In recent years there has been an increasing incidence of corporate takeovers. Typically, the takeover begins with a purchasing corporation acquiring a controlling but less than 100% interest in the target corporation. Often, the partial ownership is merely a transitory step toward complete ownership, shortly after which the target is liquidated or merged into what is now the parent corporation. In other instances, the target retains its separate corporate existence within a parent/subsidiary relationship. The choice between termination and continued corporate existence is made only after a careful appraisal of the economic and tax consequences to the parent and the …
Personal Injury Compensation As A Tax Preference,
2024
University of Maine School of Law
Personal Injury Compensation As A Tax Preference, Lawrence A. Frolik
Maine Law Review
Samuel Johnson tells us "[d]epend on it, sir, when a man knows he is to be hanged in a fortnight, it concentrates his mind wonderfully." Projected federal budget deficits in the realm of $200 billion a year for the foreseeable future ought to have a similar effect: a concentration on means of reducing these unacceptable deficits. The simple answer is either to spend less or tax more, or perhaps, a bit of both. If we choose to tax more, we must either raise tax rates or widen the tax base, or both. The former, a general rise in tax rates, …
Gifts, Joint Ownership, And Marital Property: Interspousal Transfers Of Property Under Maine's Marital Property Act,
2024
University of Maine School of Law
Gifts, Joint Ownership, And Marital Property: Interspousal Transfers Of Property Under Maine's Marital Property Act, Paul Fillmore
Maine Law Review
The classification of property in divorce proceedings as either marital or individual is crucial because under Maine's Marital Property Act a divorce decree can dispose of only marital property. Once the court identifies the marital property, the actual division of that property is within the court's discretion. Courts, however, often have difficulty classifying property which was once individual property but which was transferred by the owner spouse into joint ownership during the course of the marriage. Maine courts have reached different results in these situations depending on whether they have read the Marital Property Act literally or in the context …
Hyperlocal Gift Economies Under The Duberstein Gift Standard,
2024
University of Notre Dame Law School
Hyperlocal Gift Economies Under The Duberstein Gift Standard, Nicolás R. Munsen
Notre Dame Law Review Reflection
Hyperlocal gift economies, such as those moderated by the “Buy Nothing Project,” have become increasingly popular in the United States and abroad within the last decade. Explicitly banning the buying, selling, trading, or bartering of goods and services, hyperlocal gift economies instead encourage local community members to give to each other out of their own abundance and without any expectation of return or obligation—in short, to give and receive gifts. But while members of these groups regard these transactions as gifts, it is unclear if the Internal Revenue Service would agree. The Internal Revenue Code’s definition of “gift” in I.R.C. …
The Case For Stronger Scrutiny Of The Deductibility Of Crypto Losses,
2024
Singapore Management University
The Case For Stronger Scrutiny Of The Deductibility Of Crypto Losses, Vincent Ooi
Research Collection Yong Pung How School Of Law
My paper, The Case for Stronger Scrutiny of the Deductibility of Crypto Losses, which was recently published by The Journal of Tax Administration, discusses the issue of crypto losses and risks to the tax base. It submits that tax authorities and national legislatures should step up their scrutiny of the deductibility of crypto losses and proposes some ways in which this can be done in practice.
Guest Editorial – Special Issue: Environmental, Social, Governance, And Taxation,
2024
Singapore Management University
Guest Editorial – Special Issue: Environmental, Social, Governance, And Taxation, Vincent Ooi, Amy Lawton
Research Collection Yong Pung How School Of Law
This special issue of the eJournal of Tax Research comprises five articles that are a selection of papers that were originally presented at the SMU–Edinburgh Environmental, Social, Governance and Taxation Conference hosted by the Yong Pung How School of Law, Singapore Management University in April 2024.
Three Proposals For Fixing The Tcja,
2024
University of Michigan Law School
Three Proposals For Fixing The Tcja, Reuven S. Avi-Yonah
Articles
The year 2025 promises to be important in U.S. tax history for three reasons. First, the expiration of the individual provisions of the Tax Cuts and Jobs Act means that Congress is very likely to enact important tax legislation to prevent tax increases for millions of individual taxpayers. Second, a new administration frequently means tax legislation, typically through budget reconciliation if the same party controls Congress (1981, 1993, 2001, 2017, 2022). Third, the trifecta of Supreme Court decisions in 2024 (Moore, Corner Post, and Loper Bright) suggests that there may be a spike in litigation challenging various tax provisions as …
The Case For Stronger Scrutiny Of The Deductibility Of Crypto Losses,
2024
Singapore Management University
The Case For Stronger Scrutiny Of The Deductibility Of Crypto Losses, Vincent Ooi
Research Collection Yong Pung How School Of Law
Crypto losses have the potential to adversely impact the tax base, particularly if they are deducted against income from other profitable sources. There is a key question of fairness as to whether crypto losses should be cross-subsidised by income from other sources that may have nothing to do with cryptoassets at all. This article argues for stronger scrutiny of the deductibility of crypto losses at the stage of determining whether such losses can be set off against income from other sources or at the stage of the shifting of the losses across time and between companies. It explains why crypto …
