M'Culloch In Context,
2019
University of Arkansas, Fayetteville
M'Culloch In Context, Mark R. Killenbeck
Arkansas Law Review
M’Culloch v. Maryland is rightly regarded as a landmark opinion, one that affirmed the ability of Congress to exercise implied powers, articulated a rule of deference to Congressional judgments about whether given legislative actions were in fact “necessary,” and limited the ability of the states to impair or restrict the operations of the federal government. Most scholarly discussions of the case and its legacy emphasize these aspects of the decision. Less common are attempts to place M’Culloch within the ebb and flow of the Marshall Court and the political and social realities of the time. So, for example, very few …
Lands Of Opportunity: An Analysis Of The Effectiveness And Impact Of Opportunity Zones In The Tax Cuts And Jobs Act Of 2017,
2019
Notre Dame Law School
Lands Of Opportunity: An Analysis Of The Effectiveness And Impact Of Opportunity Zones In The Tax Cuts And Jobs Act Of 2017, Joseph Bennett
Journal of Legislation
No abstract provided.
Free Money, But Not Tax-Free: A Proposal For The Tax Treatment Of Cryptocurrency Hard Forks,
2019
Fordham University School of Law
Free Money, But Not Tax-Free: A Proposal For The Tax Treatment Of Cryptocurrency Hard Forks, Danhui Xu
Fordham Law Review
Cryptocurrency has attracted extraordinary attention as one of the greatest financial innovations in recent years. Equally noticeable are the increasingly frequent cryptocurrency events, such as hard forks. Put simply, a cryptocurrency hard fork happens when a single cryptocurrency splits in two, which results in original coin owners receiving free forked coins. Such hard forks have resulted in billions of dollars distributed to U.S. taxpayers. Despite ongoing regulatory efforts, to date, the Internal Revenue Service (IRS) has yet to take a clear position on the tax treatment of cryptocurrency hard forks. The lack of useful guidance when filing tax returns has …
United States Policy And The Taxation Of International Intangible Income,
2019
University of Miami School of Law
United States Policy And The Taxation Of International Intangible Income, Stanley I. Langbein
University of Miami Inter-American Law Review
No abstract provided.
Taxing The Robots,
2019
SMU Dedman School of Law
Taxing The Robots, Orly Mazur
Pepperdine Law Review
Robots and other artificial intelligence-based technologies are increasingly outperforming humans in jobs previously thought safe from automation. This has led to growing concerns about the future of jobs, wages, economic equality, and government revenues. To address these issues, there have been multiple calls around the world to tax the robots. Although the concerns that have led to the recent robot tax proposals may be valid, this Article cautions against the use of a robot tax. It argues that a tax that singles out robots is the wrong tool to address these critical issues and warns of the unintended consequences of …
Bearing Hospital Tax Breaks: How Non-Profits Benefit From Your Surprise Medical Bills,
2019
Georgia State University College of Law
Bearing Hospital Tax Breaks: How Non-Profits Benefit From Your Surprise Medical Bills, Taylor N. Armstrong
Georgia State University Law Review
This Note addresses the growing issue of surprise medical bills and how the United States Tax Code can be used to prevent many patients from receiving these bills. Part I provides a background on surprise billing and market factors that have led to an increase in the bills as well as current legislative solutions to the problem. Part II analyzes the role that hospitals play in the insurance market, the current standards for nonprofit hospitals to receive tax exemption under Internal Revenue Code (IRC) § 501, and how these legal standards fall short of accomplishing the goals of the tax …
Pass The Revenue: How Section 280e Is Harming The Medical Marijuana Industry,
2019
Benjamin N. Cardozo School of Law
Pass The Revenue: How Section 280e Is Harming The Medical Marijuana Industry, Liam Mckillop
Cardozo International & Comparative Law Review
The note argues that Section 280E of the Internal Revenue Code unfairly penalizes medical marijuana businesses by disallowing ordinary business expense deductions, despite their legality under state laws. It proposes that Congress should amend Section 280E to create an exception for medical marijuana companies, allowing them to deduct business expenses, thereby promoting industry growth and aligning tax policy with current societal and scientific understanding of marijuana's medical benefits.
Taxation And Reducing Recidivism: A Legal Comparative Analysis Of Reducing Recidivism In States And A Federal Solution For The Future,
2019
University of the District of Columbia School of Law
Taxation And Reducing Recidivism: A Legal Comparative Analysis Of Reducing Recidivism In States And A Federal Solution For The Future, Israel X. Nery, Scott B. Astrada
University of the District of Columbia Law Review
In this article, we will focus on employer-based tax incentives for hiring ex-offenders. Central to the discussion will be the Work Opportunity Tax Credit ("WOTC"), which provides a tax credit to employers who hire qualified employees/ex-offenders under the program. Additionally, we will explore various state programs modeled on a tax-based incentive and conduct a comparative assessment of where federal and state programs are effective and where there is potential for reform. Without targeted policy solutions to address employment obstacles, ex-offenders are left facing persistent employment barriers as they attempt to return to their communities and start a new life after …
Cooper V. Commissioner: Give The Inventor A (Learned) Hand,
2019
University of Maine School of Law
Cooper V. Commissioner: Give The Inventor A (Learned) Hand, Rebecca R. Dulik
Maine Law Review
Among the Internal Revenue Code’s many rules are some taxpayer-friendly provisions that grant tax benefits. Section 1235 is one such provision, providing to an inventor preferential tax treatment for income from the sale or exchange of a patent. In Cooper v. Commissioner, although the taxpayer inventor satisfied § 1235’s requirements, the Ninth Circuit affirmed the Tax Court’s decision to deny the taxpayer § 1235’s benefits. This Note compares Cooper to other § 1235 cases and argues that Cooper was decided wrongly because of the application of the substance over form doctrine. The substance over form doctrine is overapplied in general …
Taxing Selling Partners,
2019
University of Washington School of Law
Taxing Selling Partners, Emily Cauble
Washington Law Review
When a partner sells a partnership interest, the resulting gain or loss is treated as capital gain or loss, except to the extent that the partnership holds certain items whose sale would result in gain or loss that was not capital. Seemingly, the purpose of this regime is to prevent taxpayers from obtaining more favorable treatment by selling an interest in a partnership than what would result if the partnership were to sell its underlying assets. But given this legislative aim, the existing tax provisions produce results for taxpayers that are both unduly favorable (in that sale of a partnership …
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
