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What Is Insurance? An Analysis Of The Tax Deductibility Of Captive Insurance Premiums, John D. Patten 2022 Northern Illinois University

What Is Insurance? An Analysis Of The Tax Deductibility Of Captive Insurance Premiums, John D. Patten

Honors Capstones

What is insurance for the purposes of a tax deduction? The Internal Revenue Code does not define insurance. Without this definition, taxpayers using alternative insurance products to manage their risks must look to case law to determine whether their arrangements count as tax deductible insurance or non-deductible self-insurance. This paper dives into the four prongs of insurance: insurance risk, risk shifting, risk distributing, and commonly accepted notions of insurance. This paper looks to cases that have dealt with the deduction of captive insurance premiums to provide better insight into the practical application of this test. After discussing the evolution of ...


Written Testimony Of Philip Hackney For The Hearing On Laws And Enforcement Governing The Political Activities Of Tax-Exempt Entities (U.S. Senate Finance Committee Subcommittee On Taxation And Irs Oversight, May 4, 2022), Philip Hackney 2022 University of Pittsburgh School of Law

Written Testimony Of Philip Hackney For The Hearing On Laws And Enforcement Governing The Political Activities Of Tax-Exempt Entities (U.S. Senate Finance Committee Subcommittee On Taxation And Irs Oversight, May 4, 2022), Philip Hackney

Testimony

Are tax laws and IRS enforcement up to the task of overseeing the tax issues associated with the political activities of tax-exempt organizations? Though the tax laws governing the tax-exempt realm are wanting, our overall legal structure is not bad. It is justifiable at least. Where we fall down as a nation in this space is in the enforcement. We do not allocate enough resources to this arena, and we do not institutionally offer the support necessary to enforce these laws. These failures do not favor one party over the other but favor those interests in the country with the ...


Federal Income Taxation, Andrew Todd 2022 Mercer University School of Law

Federal Income Taxation, Andrew Todd

Mercer Law Review

In 2021, the United States Court of Appeals for the Eleventh Circuit handed down several opinions involving U.S. federal income tax issues. Two of the court’s published opinions address federal income taxation of conservation easements. Conservation easements have been under significant scrutiny by the Internal Revenue Service (IRS), having earned a spot on the “Dirty Dozen” list of tax scams in 2019. This Article surveys the two published opinions issued in 2021 involving the U.S. federal income taxation of conservation easements.


Questions The Irs Will Not Answer, Emily L. Cauble 2022 DePaul University

Questions The Irs Will Not Answer, Emily L. Cauble

Indiana Law Journal

When a taxpayer plans to undertake a transaction and its tax consequences are unclear, the taxpayer can request a letter ruling from the IRS. The IRS issues numerous letter rulings each year. In 2020, for instance, the IRS issued 777 letter rulings. The IRS refrains from issuing letter rulings on certain topics. At the beginning of each year, the IRS publishes an updated list of the topics on which it will not rule. Many of the topics on which it will not rule arise in areas of tax law governed by standards where the tax outcome depends heavily on each ...


The Intergenerational Equity Case For A Wealth Tax, Daniel Schaffa 2022 University of Cincinnati College of Law

The Intergenerational Equity Case For A Wealth Tax, Daniel Schaffa

University of Cincinnati Law Review

Intergenerational equity is commonly set aside in favor of other policy objectives, perhaps because of the extreme challenges inherent in adopting and applying an intergenerational equity normative framework. Even when there is a near consensus that the choices of today will have substantial costs in the future, these costs are often downplayed or disregarded. This Article asks whether there are measures that might offer redress to a generation for the costs imposed on it by its predecessors and finds that a one-time wealth tax is a promising option. Although its analysis applies more generally, this Article focuses on the widely ...


Is The Biggest Offer The Best Offer?, Alyssa Croft 2022 South Texas College of Law Houston

Is The Biggest Offer The Best Offer?, Alyssa Croft

Pace Intellectual Property, Sports & Entertainment Law Forum

Many people strive to be professional athletes because of the respect and accomplishment it receives. You make a lot of money, it can be glamorous, you are in commercials and magazines, and sometimes even movies. However, there are some things people do not think about when it comes to professional athletes. One of the biggest is taxation! There are so many different things athletes must think about and do because of taxes so they can take home the most amount of money possible. Athletes must be careful about who they hire to help them with their taxes because they want ...


The Pain Of Paying Taxes, Gary M. Lucas Jr 2022 Texas A&M University School of Law

The Pain Of Paying Taxes, Gary M. Lucas Jr

Faculty Scholarship

With a few caveats, standard economic models assume that, from society’s perspective, the payment of a tax constitutes a costless transfer from the taxpayer to the government. The financial loss to the taxpayer is exactly offset by the financial gain to the government, which can use the resulting tax revenue for the benefit of its citizens. In other words, paying taxes forces taxpayers to forgo private consumption, but the resulting loss in utility can be counterbalanced by an increase in utility from government spending. In fact, if the government spends wisely on beneficial public goods that are undersupplied by ...


Federally Mandated Online Sales Tax: A Logistical Solution For The Future Of E-Commerce, Daniel O'Connor 2022 Depaul University College of Law

Federally Mandated Online Sales Tax: A Logistical Solution For The Future Of E-Commerce, Daniel O'Connor

DePaul Business and Commercial Law Journal

No abstract provided.


Economic Structural Transformation And Litigation: Evidence From Chinese Provinces, To Economic Change And Restructuring, Doug Bujakowski, Joan Schmit 2022 Drake University Law School

Economic Structural Transformation And Litigation: Evidence From Chinese Provinces, To Economic Change And Restructuring, Doug Bujakowski, Joan Schmit

DePaul Business and Commercial Law Journal

No abstract provided.


The "Business Interruption" Insurance Coverage Conundrum: Covid-19 Presents A Challenge, Paul E. Traynor 2022 University of North Dakota School of Law

The "Business Interruption" Insurance Coverage Conundrum: Covid-19 Presents A Challenge, Paul E. Traynor

DePaul Business and Commercial Law Journal

No abstract provided.


Misalighned Incentives In Markets: Envisioning Finance That Benefits All Of Society, Dr. Ryan Clements 2022 University of Calgary

Misalighned Incentives In Markets: Envisioning Finance That Benefits All Of Society, Dr. Ryan Clements

DePaul Business and Commercial Law Journal

No abstract provided.


Revitalizing Downtowns Act S. 2511 (117th Congress), Tam Nguyen, MST Students BUS 223A Fall 2021 2022 San Jose State University

Revitalizing Downtowns Act S. 2511 (117th Congress), Tam Nguyen, Mst Students Bus 223a Fall 2021

The Contemporary Tax Journal

No abstract provided.


Broadening Online Opportunities Through Simple Technologies Act H.R.1362 (117th Congress), Minh Nguyet (Tracy) Than, Yulin Ke 2022 San Jose State University

Broadening Online Opportunities Through Simple Technologies Act H.R.1362 (117th Congress), Minh Nguyet (Tracy) Than, Yulin Ke

The Contemporary Tax Journal

No abstract provided.


Front Matter (Letter From The Editor, Masthead, Etc.), 2022 San Jose State University

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal’S Interview With Mr. Ray Beeman, Tam Nguyen 2022 San Jose State University

The Contemporary Tax Journal’S Interview With Mr. Ray Beeman, Tam Nguyen

The Contemporary Tax Journal

No abstract provided.


Countering Identity Theft And Strengthening Data Security Practices Across The Tax Preparer Community, Patrick Ryle JD, LLM, CPA, Assyad Al-wreikat PhD, Ellen Bartley CMA, Mark A. McKnight PhD, CFE, Brett L. Bueltel JD, CPA 2022 Dalton State College

Countering Identity Theft And Strengthening Data Security Practices Across The Tax Preparer Community, Patrick Ryle Jd, Llm, Cpa, Assyad Al-Wreikat Phd, Ellen Bartley Cma, Mark A. Mcknight Phd, Cfe, Brett L. Bueltel Jd, Cpa

The Contemporary Tax Journal

No abstract provided.


An Introduction To The Tax Intricacies Of Executive Compensation, Jane Lei CPA 2022 San Jose State University

An Introduction To The Tax Intricacies Of Executive Compensation, Jane Lei Cpa

The Contemporary Tax Journal

No abstract provided.


Summaries From The 2021 37thannual Tei-Sjsu High Tech Tax Institute And The 27th Annual Tax Practitioner/Irs Fall Seminar, Inessa Zlobina EA, Priti Trivedi, Tam Nguyen, Dale Loepp CPA 2022 San Jose State University

Summaries From The 2021 37thannual Tei-Sjsu High Tech Tax Institute And The 27th Annual Tax Practitioner/Irs Fall Seminar, Inessa Zlobina Ea, Priti Trivedi, Tam Nguyen, Dale Loepp Cpa

The Contemporary Tax Journal

No abstract provided.


Cpa Exam Review Questions Provided Courtesy Of Gleim Cpa Review, 2022 San Jose State University

Cpa Exam Review Questions Provided Courtesy Of Gleim Cpa Review

The Contemporary Tax Journal

No abstract provided.


The Tax Gap: Do Billions In Uncollected Income Taxes Speed Up Economic Downturn During A Global Pandemic?, Offiong Ekah 2022 Pepperdine University

The Tax Gap: Do Billions In Uncollected Income Taxes Speed Up Economic Downturn During A Global Pandemic?, Offiong Ekah

Journal of the National Association of Administrative Law Judiciary

Section I will explore how maximizing taxpayer compliance will be a crucial component of closing the tax gap, and what initiatives the IRS implements to garner compliance; Section I will also examine how past and current Tax Code affects levels of compliance—the goal always being compliance optimization. Section II will explore the CARES Act of 2020, and how the Act fared as a response to the onset of COVID-19. This section will also discuss how the concerns of the IRS are accentuated by the tax gap, and how a lack of governmental funding, particularly relating to detailed exclusions enumerating ...


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