Response To 'Reverse Al Capone-Ism' And The Tax Treatment Of Marijuana Businesses,
2019
University of Michigan Law School
Response To 'Reverse Al Capone-Ism' And The Tax Treatment Of Marijuana Businesses, Douglas A. Kahn, Howard J. Bromberg
Other Publications
Mr. Silverberg’s comment stresses that the proponents of the legalization of marijuana have not been able to convince Congress to legalize it, and so it is appropriate for Congress to penalize trafficking in that drug. Apparently, he sees our contention that the penalty adopted in I.R.C. § 280E is irrational and contravenes established punitive jurisprudence as a backdoor attempt to accomplish indirectly, by weakening the penalties on the marijuana businesses, what has not been able to be accomplished by those seeking its federal legalization. That was not the motive for our proposal and is not a fair reading of our …
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018,
2019
San Jose State University
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018, Inna Ostrovsky, Joanna Levasseur
The Contemporary Tax Journal
No abstract provided.
Fun Tax Facts,
2019
San Jose State University
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019,
2019
San Jose State University
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill,
2019
San Jose State University
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.),
2019
San Jose State University
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
Summaries From The 34th Annual High Tech Tax Institute,
2019
San Jose State University
Summaries From The 34th Annual High Tech Tax Institute, Amy Yue Cpa, Langzun Li, Rachana Khandelwal, Nam Nguyen
The Contemporary Tax Journal
No abstract provided.
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones,
2019
San Jose State University
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones, Inna Ostrovsky
The Contemporary Tax Journal
No abstract provided.
Roger Cpa Review Questions,
2019
San Jose State University
Roger Cpa Review Questions, Roger Philipp Cpa, Cgma
The Contemporary Tax Journal
No abstract provided.
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute,
2019
San Jose State University
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute, Chen Chen, Liwei Bi, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
South Dakota V. Wayfair: Analysis And State Reaction,
2019
East Carolina Unversity
South Dakota V. Wayfair: Analysis And State Reaction, Andrew M. Wasilick, Dan L. Schisler Phd., Cpa
The Contemporary Tax Journal
No abstract provided.
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress),
2019
San Jose State University
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress), Langzun Li
The Contemporary Tax Journal
No abstract provided.
A Georgist Perspective Of Petroleum Taxation,
2019
Indiana University Maurer School of Law
A Georgist Perspective Of Petroleum Taxation, Joseph Leeson
Indiana Journal of Global Legal Studies
Over a century ago, the town of Arden, Delaware, was founded on a unique single-tax-community system that radically altered the popular concept of land ownership. This system was premised on concepts developed by a man few know today but who was a major figure in economics during the 1800s, Henry George. George's public finance theory has been described as having received "intermittent attention over the years, with many eminent names in economics making at least a passing comment, but it has seen comparably little action in the policy debate arena and has been largely ignored by the modern era of …
Toward A 21st-Century International Tax Regime,
2019
University of Michigan Law School
Toward A 21st-Century International Tax Regime, Reuven S. Avi-Yonah, Kimberly A. Clausing
Articles
The international tax regime is almost a century old, and it is showing its age. In recent decades, the regime could be maintained despite increasing evidence that some of its key components, such as the arm’s-length standard or permanent establishment threshold, were unfit for a 21st-century economy. However, starting with the U.K. diverted profits tax (2015), Australia’s multinational anti-tax-avoidance law (2015), and India’s equalization levy (2016), it has become clear that many countries are unwilling to live with a situation in which large U.S. technology companies (such as Amazon, Apple, Facebook, Google, and Netflix) earn billions in profits by exploiting …
If Not Now, When? U.S. Tax Treaties With Latin America After Tcja,
2019
University of Michigan Law School
If Not Now, When? U.S. Tax Treaties With Latin America After Tcja, Reuven S. Avi-Yonah
Articles
Since the 1990s, the US tax treaty network has expanded to include most large developing countries. However, there remains a glaring exception: The US only has two tax treaties in Latin America (Mexico and Venezuela), and one pending tax treaty (Chile). The traditional explanation for why the US has no treaty with, for example, Argentina or Brazil is the US refusal since 1957 to grant tax sparing credits to developing countries. Before the Tax Cuts and Jobs Act of 2017 (TCJA), this explanation was wrong, because the combination of deferral and cross-crediting meant that tax holidays in a source country …
Executive Compensation In The Charitable Sector: Beyond The Tax Cuts And Jobs Act,
2019
Vanderbilt University Law School
Executive Compensation In The Charitable Sector: Beyond The Tax Cuts And Jobs Act, Lauren Rogal
Vanderbilt Law School Faculty Publications
The Tax Cuts and Jobs Act of 2017 (“TCJA”) reformed charity executive compensation for the first time in decades, introducing an across-the-board excise tax on compensation over $1 million.1 Its enactment represents a significant step toward securing accountability for the use of the charitable tax exemption under Section 501(c)(3) of the Internal Revenue Code. These organizations receive preferential tax treatment to subsidize their provision of socially beneficial outputs that would otherwise be undersupplied. Overcompensation of charity executives subverts this purpose by diverting those subsidies for private gain and undermining public confidence in the charitable sector.
With the enactment of the …
The Superiority Of The Digital Service Tax Over Significant Digital Presence Proposals,
2019
Allard School of Law at the University of British Columbia
The Superiority Of The Digital Service Tax Over Significant Digital Presence Proposals, Wei Cui
All Faculty Publications
Responding to calls for reallocating taxing rights over multinationals’ profits to reflect the place of user value creation, the OECD recently announced a Program of Work to implement international tax reform. I use the European Commission’s 2018 proposal to introduce the “significant digital presence” concept into income tax treaties as an example of the type of approach the OECD favors, and argue that it is inferior to recently proposed digital services taxes (DSTs). DSTs directly address the question of where profits should be allocated and taxed, while SDP proposals subordinate this vital question to superfluous treaty conventions. Global tax coordination …
Foreword,
2019
Washington and Lee University School of Law
Foreword, Michelle Lyon Drumbl
Washington and Lee Journal of Civil Rights and Social Justice
Michelle L. Drumbl, Clinical Professor of Law and Director of the Tax Clinic at W&L Law, introduces this issue of the Journal of Civil Rights and Social Justice, which includes material presented at and inspired by the Journal's 2018 symposium, Always with Us? Poverty, Taxes, and Social Policy.
A Typology Of Place-Based Investment Tax Incentives,
2019
University of Illinois College of Law
A Typology Of Place-Based Investment Tax Incentives, Michelle D. Layser
Washington and Lee Journal of Civil Rights and Social Justice
This Article makes several contributions to tax, poverty, and empirical legal literature. First, it defines the category of place-based investment tax incentives and identifies key elements of variation across the category. Despite their prevalence at all levels of government, place-based investment tax incentives remain undertheorized and largely undefined in the literature. The typology presented here reflects an analysis of three federal tax incentives (the New Markets Tax Credit, the Low-Income Housing Tax Credit, and the new Opportunity Zones law) and a detailed survey of tax incentives included in state enterprise zone laws. By defining this category of tax laws and …
Converging Welfare States: Symposium Keynote,
2019
University of Wisconsin Law School
Converging Welfare States: Symposium Keynote, Susannah Camic Tahk
Washington and Lee Journal of Civil Rights and Social Justice
Susannah Camic Tahk, Associate Dean for Research and Faculty Development and Associate Professor of Law at the University of Wisconsin Law School, speaks to the Journal of Civil Rights and Social Justice 2018 symposium, Always with Us? Poverty, Taxes, and Social Policy. She addresses the following questions: To what extent do the particular advantages of the tax antipoverty programs persist as the tax antipoverty programs take center stage? Can tax programs, once distinguished from their direct-spending counterparts on the grounds of relative popularity and legal and administrative ease of access maintain those hallmarks as the tax-based welfare state grows …
