The Tax Cuts And Jobs Act Of 2017: The Salt Deduction, Tax Competition, And Double Taxation,
2019
University of San Diego
The Tax Cuts And Jobs Act Of 2017: The Salt Deduction, Tax Competition, And Double Taxation, William B. Barker
San Diego Law Review
The Tax Cuts and Jobs Act of 2017 (TCJA) made many changes to federal income tax law, but none of them may be as important to the functioning of our federal system as the changes the Act made to the deduction for state and local taxes. The Act, by decreasing taxpayer savings for state and local tax expenditures in both obvious and obscure ways, has substantially increased the burden of paying state and local taxes and is a major threat to state and local government ability to tax for public benefits. The threat to state governments is demonstrated by the …
The Nonprofit Sector's Uncertain Future In A Post-Tcja America,
2019
Brigham Young University Law School
The Nonprofit Sector's Uncertain Future In A Post-Tcja America, Jt Alston
BYU Law Review
The tax deduction for charitable contributions has existed in the Internal Revenue Code in some form since the early 1900s. While the charitable deduction has been preserved in the U.S. tax code for more than 100 years, the Tax Cuts and Jobs Act (TCJA) of December 2017 threatens charities by removing the tax incentive to donate to charity from all but the wealthiest taxpayers. Both charities and nonprofits play a vital role in the U.S. economy by providing some goods and services more efficiently than the public or private sectors. In this Note I explore the role of nonprofits in …
Section 1031 Like-Kind Exchange,
2019
San Jose State University
Section 1031 Like-Kind Exchange, Daniel Currie
The Contemporary Tax Journal
No abstract provided.
Taxation Of Cryptocurrency Hard Forks,
2019
San Jose State University
Taxation Of Cryptocurrency Hard Forks, Rachana Khandelwal
The Contemporary Tax Journal
No abstract provided.
Section 195,
2019
Alfred University
Section 195, Luis Rodriguez Jr., Mba, Jd, Llm
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview With Eileen Marshall,
2019
San Jose State University
The Contemporary Tax Journal’S Interview With Eileen Marshall, Rani Vaishnavi Kothapalli
The Contemporary Tax Journal
No abstract provided.
Tax Treaties And Special Considerations For Unemployment Income, Foreign Students, And Academic Employees,
2019
San Jose State University
Tax Treaties And Special Considerations For Unemployment Income, Foreign Students, And Academic Employees, Inna Ostrovsky
The Contemporary Tax Journal
No abstract provided.
Short Sales And Cancellation Of Debt Income,
2019
San Jose State University
Short Sales And Cancellation Of Debt Income, Rani Vaishnavi Kothapalli
The Contemporary Tax Journal
No abstract provided.
Roger Cpa Review,
2019
San Jose State University
Roger Cpa Review, Roger Philipp Cpa, Cgma
The Contemporary Tax Journal
No abstract provided.
Summaries For The 6th Annual Irs-Sjsu Small Business Tax Institute,
2019
San Jose State University
Summaries For The 6th Annual Irs-Sjsu Small Business Tax Institute, Daniel Currie, Ruchi Chopra, Chen Chen, Sara Yaqin Sun, Surbhi Doshi, Tina Tran
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 8, No. 1 – Winter 2019,
2019
San Jose State University
The Contemporary Tax Journal Volume 8, No. 1 – Winter 2019
The Contemporary Tax Journal
No abstract provided.
Fun Tax Facts,
2019
San Jose State University
H.R.3708 – 115th Congress (2017-2018) – The Cryptocurrency Tax Fairness Act,
2019
San Jose State University
H.R.3708 – 115th Congress (2017-2018) – The Cryptocurrency Tax Fairness Act, Rachana Khandelwal
The Contemporary Tax Journal
No abstract provided.
Complete Distributive Rules And The Single Tax Principle: A Review Of Recent Italian Case Law,
2019
University of Michigan Law School
Complete Distributive Rules And The Single Tax Principle: A Review Of Recent Italian Case Law, Reuven S. Avi-Yonah, Gianluca Mazzoni
Articles
The authors, in this article, examine the application of complete distributive rules as set out in various tax treaties as it relates to the single tax principle by reference to recent Italian case law.
On 11 October 2018, in Decision No. 25219, the Italian Corte Suprema di Cassazione (Supreme Court, CSC) confirmed that treaty provisions limiting the exercise of the domestic power to tax by the source state also apply where the residence state does not actually tax the relevant item of income. In that case, where a tax treaty attributes exclusive tax jurisdiction over an item of income to …
Table Of Contents,
2019
Seattle University School of Law
Table Of Contents, Seattle University Law Review
Seattle University Law Review
No abstract provided.
The Practice And Tax Consequences Of Nonqualified Deferred Compensation,
2019
Boston University School of Law
The Practice And Tax Consequences Of Nonqualified Deferred Compensation, David I. Walker
Washington and Lee Law Review
Although nonqualified deferred compensation plans lack explicit tax preferences afforded to qualified plans, it is well understood that nonqualified deferred compensation results in a joint tax advantage when employers earn a higher after-tax return on deferred sums than employees could achieve on their own. But the joint tax advantage depends critically on how plans are operated; chiefly how plan sponsors use or invest deferred compensation dollars. This is the first Article to systematically investigate nonqualified deferred compensation practices. It shows that joint tax minimization historically has taken a backseat to accounting priorities and participant diversification concerns. In recent years, the …
The Games They Will Play: Tax Games, Roadblocks, And Glitches Under The 2017 Tax Legislation,
2019
NYU School of Law
The Games They Will Play: Tax Games, Roadblocks, And Glitches Under The 2017 Tax Legislation, David Kamin, David Gamage, Ari Glogower, Rebecca Kysar, Darien Shanske, Reuven S. Avi-Yonah, Lily Batchelder, J. Clifton Fleming, Daniel Hemel, Mitchell Kane, David Miller, Daniel Shaviro, Manoj Viswanathan
Articles
The 2017 tax legislation brought sweeping changes to the rules for taxing individuals and business, the deductibility of state and local taxes, and the international tax regime. The complex legislation was drafted and passed through a rushed and secretive process intended to limit public comment on one of the most consequential pieces of domestic policy enacted in recent history. This Article is an effort to supply the analysis and deliberation that should have accompanied the bill’s consideration and passage, and describes key problem areas in the new legislation. Many of the new changes fundamentally undermine the integrity of the tax …
Taxation Of Automation And Artificial Intelligence As A Tool Of Labour Policy,
2019
Singapore Management University
Taxation Of Automation And Artificial Intelligence As A Tool Of Labour Policy, Vincent Ooi, Glendon Goh
Centre for AI & Data Governance (2019-2025)
Rapid developments in automation technology pose a risk of massdisplacement of human labour, resulting in the need to support and retraindisplaced workers (a negative externality). We propose an “automation tax”that would slow the adoption of automation technology in appropriatecircumstances, giving workers and social support systems time to adapt. Thiscould be easily implemented through changes to the existing schedular systemof depreciation/ capital allowances, reducing the uncertainty of its applicationand implementation costs. Such a system would be flexible enough to keepup with rapid technological developments. Two main dimensions may beadjusted to produce intended distortionary effects: 1) accelerated depreciation,and 2) bonus depreciation. While …
Insulation By Separation: When Dual-Class Stock Met Corporate Spin-Offs,
2019
University of Utah, SJ Quinney College of Law
Insulation By Separation: When Dual-Class Stock Met Corporate Spin-Offs, Young Ran Kim, Geeyoung Min
Utah Law Faculty Scholarship
The recent rise of shareholder engagement has revamped companies’ corporate governance structures so as to empower shareholder rights and to constrain managerial opportunism. Notwithstanding the general trend, this Article uncovers corporate spin-off transactions — which divide a single company into two or more companies — as a unique mechanism that insulates the management from shareholder intervention. In a spin-off, the company’s managers can fundamentally change the governance arrangements of the new spun-off company without being subject to monitoring mechanisms, such as shareholder approval or market check. Those changes often empower managers over shareholders. Furthermore, most spin-off transactions enjoy tax benefits. …
Beps And The Emerging Global Approach To Taxing Multinational Enterprises,
2019
Osgoode Hall Law School of York University
Beps And The Emerging Global Approach To Taxing Multinational Enterprises, Jinyan Li, Jin Bao, Huaning (Christina) Li
Conference Papers
The G20/OECD Base Erosion and Profit Shifting (BEPS) Project aimed at revising existing tax rules to align the taxation of profit with the location of economic activities and value creation (the “value creation principle”). It has received much commentary in literature and general debates and has been regarded as “the most significant re-write of the international tax rules in a century”, an opportunity to “rebuild a healthy scheme for allocating taxation rights”, having the potential to significantly alter the contours of the international tax regime, transforming the international tax regime, signaling a “new struggle over international taxation”, or representing the …
