Taxation-Federal Commons^™

Early Termination Of A Trust, Jeffrey H. Kahn, Douglas A. Kahn

Scholarly Publications

No abstract provided.

The Enigma Of Wynne, Edward A. Zelinsky

William & Mary Business Law Review

The five-justice Wynne majority used that case to make a major statement about the dormant Commerce Clause. In many respects, Wynne is an enigma that perpetuates an inherent problem of the Court’s dormant Commerce Clause doctrine: the Court declares some ill-defined taxes as unconstitutionally discriminatory because they encourage in-state investment, while other economically equivalent taxes and government programs that similarly encourage intrastate economic activity are apparently acceptable under the dormant Commerce Clause.

Wynne is thus more important than the immediate situation it addresses, and will have consequences beyond the immediate circumstances it addresses. A decision as enigmatic as it is …

Words Of Wisdom From The Founding Fathers: Why The Internal Revenue Service Should Let Churches Be, Sophia Benavides

Journal of the National Association of Administrative Law Judiciary

Part I of this comment will explore the foundations of the First Amendment, as the Constitution is a framework on which the United States continues to rest. An examination of the events contributing and leading to the drafting of the Constitution will illuminate the rationale behind the tenets put forth by the Founding Fathers. More specifically, this comment will devote emphasis to the Founding Fathers’ objectives regarding the state in relation to religion. This emphasis will provide insight into the perspective of the Founders at the time of drafting the First Amendment. Furthermore, this section will illustrate how the separation …

Registered Savings Plans And The Making Of Middle Class Canada: Toward A Performative Theory Of Tax Policy, Lisa Philipps

Articles & Book Chapters

Politicians across Canada’s political spectrum strive to position themselves as defenders of the middle class, and tax policy is a prime vehicle for making this pitch. Any tax reform proposal can be examined critically to evaluate its likely distributional impacts and how well these map onto specific definitions of the middle class. This article attempts, however, a different project. Drawing on the ideas of Judith Butler, it analyzes instead how tax policy produces middle-class identity through the very process of claiming to advance middle-class interests. The case study for this purpose is the rise of tax incentives for saving as …

Tax Treaties-Reciprocal Exchange Of Information-Summons Power Contained In Irc Section 7602 May Be Used To Obtain Information From Domestic Sources For Use By Canadian Authorities In Investigating The Canadian Tax Liability Of A Canadian Company, Tim J. Floyd

Georgia Journal of International & Comparative Law

No abstract provided.

Is An American Value Added Tax Inevitable?, Steve R. Johnson

Scholarly Publications

No abstract provided.

Bringing Continuity To Cryptocurrency: Commercial Law As A Guide To The Asset Categorization Of Bitcoin, Evan Hewitt

Seattle University Law Review

This Note will undertake to analyze bitcoin under the Uniform Commercial Code (UCC) and the Internal Revenue Code (IRC)—two important sources of commercial law—to see whether any existing asset categories adequately protect bitcoin’s commercial viability. This Note will demonstrate that although commercial law dictates that bitcoin should—nay must—be regulated as a currency in order to sustain its existence, the very definition of currency seems to preclude that from happening. Therefore, this Note will recommend that we experiment with a new type of asset that receives currency-like treatment, specifically designed for cryptocurrencies, under which bitcoin can be categorized in order to …

Consolidation Of Educational Tax Credits, Michael Hynson

The Contemporary Tax Journal

No abstract provided.

Irs Developments And Examination Strategies, Aaron Grey

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal Volume 5, No. 2 – Winter 2016

The Contemporary Tax Journal

No abstract provided.

Analysis Of The Federal Estate Tax, Rachita Kothari

The Contemporary Tax Journal

No abstract provided.

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

The Contemporary Tax Journal

No abstract provided.

A Panel Discussion Of Recent Developments In State Tax Reform, Leonel Renteria

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal’S Interview Of Eli Dicker, Shruti Raja

The Contemporary Tax Journal

No abstract provided.

Cloud Activities And Issues Under Irc Sections 41 And 199, Marina Pinato

The Contemporary Tax Journal

No abstract provided.

When Should Bitcoin Be Subject To Fbar?, Arash Kiadeh

The Contemporary Tax Journal

No abstract provided.

The Altera Case: Tax Ramifications Of Stock-Based Compensation, Sandhya Dharani

The Contemporary Tax Journal

No abstract provided.

To Win Or Not To Win! Article On Prize And Awards, Shilpa Balnadu

The Contemporary Tax Journal

No abstract provided.

Repeal The Alternative Minimum Tax, Branden Wilson

The Contemporary Tax Journal

No abstract provided.

Redefining “Peril”—Abating The Interest On A Tax Deficiency For Good Faith Reliance On Irs Publications, Brady Cox

Pepperdine Law Review

Many taxpayers rely on guidance materials the IRS provides in order to comprehend the United States Tax Code and pay an accurate tax. However, many, if not all, of these taxpayers would likely be startled to learn that their reliance on these IRS guidance materials is perilous. That is, that reliance upon these guidance materials will not support a taxpayer’s tax treatment decisions if the IRS decides that the decisions were incorrect under substantive law. However, because the courts have not decisively concluded which financial consequences a taxpayer faces or escapes by relying on informal IRS guidance, “peril” remains undefined. …