2016 Trying Times: Important Lessons To Be Learned From Recent Federal Tax Cases,
2016
S.J. Quinney College of Law, University of Utah
2016 Trying Times: Important Lessons To Be Learned From Recent Federal Tax Cases, Nancy Mclaughlin
Utah Law Faculty Scholarship
Since 2005, the courts have collectively issued more than 80 opinions involving challenges to deductions claimed under IRC § 170(h) with regard to conservation and facade easement donations. This outline provides a brief history of developments in the deduction context, discusses the practical implications of the recent court decisions, and offers advice on how to file a tax return package to minimize the risk of audit. It also briefly notes various other important issues, such as the IRS's focus on valuation and syndicated deals, quid pro quo, and reserved development rights.
Summaries For The Fourth Annual Irs/Sjsu Small Business Tax Institute,
2016
San Jose State University
Summaries For The Fourth Annual Irs/Sjsu Small Business Tax Institute, Padmini Yalamarthi, Fan Wang, Jie Shen, Xuan Hong, Marla Hampton Cpa, Mba, Aaron Grey
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.),
2016
San Jose State University
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 6, No. 1 – Summer/Fall 2016,
2016
San Jose State University
The Contemporary Tax Journal Volume 6, No. 1 – Summer/Fall 2016
The Contemporary Tax Journal
No abstract provided.
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.).,
2016
McClain, Mellen, Bowling & Hickman
Book Review: International Tax Planning. By Barry Spitz. London, England: Butterworth & Co. Ltd., 1972. Pp. Xxiii, 159. $12.15 (U.S.)., Donald O. Clark
Georgia Journal of International & Comparative Law
No abstract provided.
The Concept Of Church In The 1954 Internal Revenue Code,
2016
St. John's University School of Law
The Concept Of Church In The 1954 Internal Revenue Code, Joseph D. Garland, William F. Cahill
The Catholic Lawyer
No abstract provided.
Professor Elaine Gagliardi On The Magical Power Of Appointment: Allows Trustor To Achieve Targeted Tax Consequences And Flexibility Of Control,
2016
Alexander Blewett III School of Law at the University of Montana
Professor Elaine Gagliardi On The Magical Power Of Appointment: Allows Trustor To Achieve Targeted Tax Consequences And Flexibility Of Control, Elaine H. Gagliardi
Faculty Journal Articles & Other Writings
As children, and sometimes as adults, we wish for magical powers to order the world in the way we want. Estate planners can make that wish come true for some clients and beneficiaries with judicious use of powers of appointment. Powers of appointment are uniquely suited to achieving targeted planning goals and increasing trust flexibility. Planning techniques, old and new, including the oft used Crummey trust1 and the more recently developed array of acronym trusts designed to achieve specific tax consequences, such as the intentionally defective grantor trust (IDGT)2 and the Delaware incomplete non-grantor trust (DING)3 to name a few, …
The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016,
2016
San Jose State University
The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016
The Contemporary Tax Journal
No abstract provided.
Analysis Of The Federal Estate Tax,
2016
San Jose State University
Analysis Of The Federal Estate Tax, Rachita Kothari
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.),
2016
San Jose State University
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
When Should Bitcoin Be Subject To Fbar?,
2016
San Jose State University
When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh
The Contemporary Tax Journal
No abstract provided.
Repeal The Alternative Minimum Tax,
2016
San Jose State University
Repeal The Alternative Minimum Tax, Branden Wilson
The Contemporary Tax Journal
No abstract provided.
Lack Of Marketability And Minority Discounts In Valuing Close Corporation Stock: Elusiveness And Judicial Synchrony In Pursuit Of Equitable Consensus,
2016
Barry University
Lack Of Marketability And Minority Discounts In Valuing Close Corporation Stock: Elusiveness And Judicial Synchrony In Pursuit Of Equitable Consensus, Stephen J. Leacock
Faculty Scholarship
No abstract provided.
Cross-Deductions In The Net Investment Income Tax Imposed On A Trust Or Estate With Separate Shares,
2016
California Western School of Law
Cross-Deductions In The Net Investment Income Tax Imposed On A Trust Or Estate With Separate Shares, Michael T. Yu
Faculty Scholarship
Part I of this article first provides a general overview of §§ 1411 and 663(c) and the interaction between them and the respective regulations thereunder and then proposes a revised regulation to clarify the relationship between and among the two sections and their regulations. Part II discusses the possibility of certain cross-deductions under § 1411, in conjunction with §§ 661, 662, and 663(c). Finally, Part III presents and discusses a proposed calculation and allocation, to the separate shares of a trust or estate, of income and deduction items entering into the computation of NII and DNI of the trust or …
Oklahoma Tax Commission V. United States: Death Taxes On Restricted Indian Personalty,
2016
University of South Dakota School of Law
Oklahoma Tax Commission V. United States: Death Taxes On Restricted Indian Personalty, Thomas Simmons
Faculty Publications
No abstract provided.
Why Tax Wealth Transfers?: A Philosophical Analysis,
2016
University of Kentucky College of Law
Why Tax Wealth Transfers?: A Philosophical Analysis, Jennifer Bird-Pollan
Law Faculty Scholarly Articles
The one-hundredth anniversary of the estate tax provides an ideal moment to reflect on the role of wealth transfer taxation in the larger scheme of the U.S. tax system. Wealth and income inequality are at historically high levels, and the responses to these issues are often reduced to a simplistic political dichotomy of “right” versus “left.” The multitude of views of the American people cannot be reduced to such simple generalities without losing important nuances. This Article identifies three general categories of political philosophical viewpoints that are commonly endorsed by both politicians and everyday Americans, and then examines the current …
Utilitarianism And Wealth Transfer Taxation,
2016
University of Kentucky College of Law
Utilitarianism And Wealth Transfer Taxation, Jennifer Bird-Pollan
Law Faculty Scholarly Articles
This article is the third in a series examining the continued relevance and philosophical legitimacy of the United States wealth transfer tax system from within a particular philosophical perspective. The article examines the utilitarianism of John Stuart Mill and his philosophical progeny and distinguishes the philosophical approach of utilitarianism from contemporary welfare economics, primarily on the basis of the concept of "utility" in each approach. After explicating the utilitarian criteria for ethical action, the article goes on to think through what Mill's utilitarianism says about the taxation of wealth and wealth transfers, the United States federal wealth transfer tax system …
Valuation, Values, Norms: Proposals For Estate And Gift Tax Reform,
2016
Elisabeth Haub School of Law
Valuation, Values, Norms: Proposals For Estate And Gift Tax Reform, Bridget J. Crawford
Elisabeth Haub School of Law Faculty Publications
In their contributions to this Symposium, Professor Joseph Dodge, Professor Wendy Gerzog, and Professor Kerry Ryan offer concrete proposals for improving the existing estate and gift tax system. Professor Dodge and Professor Gerzog are especially interested in accuracy in valuation, and advance specific proposals with respect to split-interest transfers and family limited partnerships. Professor Dodge makes an additional proposal to improve the generation-skipping transfer tax system, an understudied area of the law. Professor Gerzog's Symposium contribution draws particular attention to the legal fiction on which the estate and gift tax marital deductions rely. She would restrict the availability of the …
Toward A Reality-Based Estate Tax,
2016
University of Baltimore School of Law
Toward A Reality-Based Estate Tax, Wendy C. Gerzog
All Faculty Scholarship
Currently, the estate tax does not accurately value the property and transactions that it is meant to cover. Additionally, the marital and charitable deductions do not reflect actual associated transfers, instead skewing their benefits away from their purported beneficiaries. This Article proposes reforming the estate tax by eliminating these sources of unreality and distortion, and to make the current estate tax a reality-based tax. Through six specific proposals, the Article identifies solutions to the problems associated with testamentary transfers, puts forth alternative methods of valuation to prevent gaming of transfer taxes, and offers significant modifications to two deduction provisions.
Irwin V. Gavit: Income Is (Sometimes) In The Eye Of The Beholder,
2016
New York Law School
Irwin V. Gavit: Income Is (Sometimes) In The Eye Of The Beholder, William P. Lapiana
Articles & Chapters
No abstract provided.
