Taxation-Federal Commons^™

Bruyea V. United States - Latest Foreign Tax Credit Case On The Niit Sheds Important Light On Treaty Double Tax Articles, William Skinner

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, Junli Zhang

The Contemporary Tax Journal

No abstract provided.

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.)

The Contemporary Tax Journal

No abstract provided.

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), Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

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!, 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, Cynthia Flores

The Contemporary Tax Journal

No abstract provided.

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 …

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, 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, …

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. …

¿No Pagan Taxes? Overview Of Federal Revenue-Raising In Puerto Rico, 2024, Carlos Vargas-Ramos, Javier Mendez Lacomba, Jorge Soldevilla-Irizarry

CUNY Centro, The Center for Puerto Rican Studies

Residents of Puerto Rico pay federal taxes. They did so to the tune of $5 billion in 2023. They have paid more than $3 billion a year in net contributions to the federal treasury for more than 10 years in a row. This is not a secret, but rather factual information that is publicly available. Yet, it is factual information that is not widely known. Moreover, it is information that flies in the face of the “people in Puerto Rico do not pay federal taxes” narrative. The volume of federal tax contributions originating in Puerto Rico reflects the rather dynamic …

Taxing Sugar Babies, Bridget J. Crawford

Minnesota Law Review Vols. 106:2 onward (2021-present)

How people talk about tax reflects both personal beliefs and larger cultural attitudes. In many cases, whether and how a potential taxpayer understands their activities in tax terms may also reveal attitudes about themselves and the value that society assigns to those activities. This Article examines how sugar daddies and sugar babies talk about taxes in two Internet discussion forums to reveal the ongoing stigma associated with sex work. Through mostly content analysis, the focus is on the attitudes of sugar daddies and sugar babies toward taxation and the filing positions they take, as well as how tax professionals intervene …

A New Governance Framework In Cross-Border Tax Policymaking, Tamir Shanan, Doron Narotzki, Noam Zamir

Brooklyn Journal of Corporate, Financial & Commercial Law

The first tax treaty can probably be traced to the end of the 19th century: the treaty between the Swiss Federal Council (on behalf of the Canton of Vaud) and Great Britain. However, most tax scholars refer to the period following World War I, including the work of the League of Nations, as the formative period in which the international tax regime was founded. In the 1920s, the League of Nations formed a committee of four renowned economists that was asked to formulate a set of rules that would assist states in allocating taxing rights of cross-border income and gains …

Driving Corporate Environmental Responsibility With Tax Incentives And Carbon Taxation, Riya Dhall

Journal of Law and Policy

In response to the worsening global climate crisis, this Note examines the potential role of tax policy in encouraging corporate environmental responsibility. Focusing on tax incentives and a proposed federal carbon tax, it explores how strategic tax measures could drive corporations to mitigate their environmental impact. Through an analysis of economic and regulatory measures, such as cap-and-trade and excise taxes, alongside recent legislation like the Inflation Reduction Act, this Note assesses the potential of tax credits and carbon taxes to reduce corporate emissions. It further discusses the emergence of benefit corporations, specifically B Corp certified companies, such as Patagonia and …

The Equal Pay Game Changer: Using Mandatory Reporting To Encourage Corporations In The Sports Ecosystem To Increase Investment In Women’S Sports, Caroline Strauss

Journal of Law and Policy

In 2016, the United States Women’s National Team began a lengthy fight for equal pay by filing a complaint with the Equal Employment Opportunity Commission. In 2019, the fight continued when the team sued the United States Soccer Federation for gender discrimination. When the court granted summary judgment to the U.S. Soccer Federation on their Equal Pay Act claim, it closed the door for the team to achieve equal pay through a public law remedy. The tedious fight came to an end with a settlement which guaranteed that the U.S. Men’s and Women’s National Teams would be paid equally. Although …

Shaping Preferences With Pigouvian Taxes, Gary M. Lucas Jr.

Faculty Scholarship

A Pigouvian tax is a tax that is imposed to correct an externality, which arises when a person engages in behavior that harms others without their consent. Pigouvian taxes are popular among academics—with prominent economists and legal scholars arguing for their imposition on myriad goods and activities that harm third parties, like carbon emissions and alcohol. Policymakers have recently been receptive to at least some of these arguments as evidenced by taxes imposed on or proposed for a variety of externality-generating goods, including guns, plastic bags, and sugary drinks.

The conventional economic rationale for Pigouvian taxes assumes that they affect …

Taxation's Limits, Luís C. Calderón Gómez

Northwestern University Law Review

Countless pages have been devoted to the question of why everyone should pay tax, yet its opposite has gone largely unnoticed: why should some people and organizations not pay tax? Our tax system exempts from ordinary income taxation a wide and diverse array of people and organizations engaged in significant economic activity—from parents providing childcare services for their family to consular activities and charities operating animal shelters—seemingly without a convincing explanation. Perhaps because of the dizzying diversity of tax-exempt activities, scholars and policymakers have avoided comprehensively or coherently justifying our exemption regimes.

This Article develops a novel normative theory that …