Why Section 530 Of The Revenue Act Of 1978 Applies To The States,
2014
Algorithm LLC
Why Section 530 Of The Revenue Act Of 1978 Applies To The States, David Randall Jenkins
The Contemporary Tax Journal
No abstract provided.
An Examination Of The Tax Incentive For Child Support,
2014
Texas Tech University College of Business
An Examination Of The Tax Incentive For Child Support, Gary M. Fleischman, Paul Hutchison, Zafar Dad Khan
The Contemporary Tax Journal
No abstract provided.
Net Investment Income Tax Planning,
2014
William & Mary Law School
Net Investment Income Tax Planning, Jeanne M. Sullivan
William & Mary Annual Tax Conference
No abstract provided.
Pro And Con (Law): Considering The Irrevocable Nongrantor Trust Technique,
2014
Vanderbilt University Law School
Pro And Con (Law): Considering The Irrevocable Nongrantor Trust Technique, Alyssa A. Dirusso
Vanderbilt Law Review
Commentary on Jeffrey Schoenblum, Strange Bedfellows: The Federal Constitution, Out-of-State Nongrantor Accumulation Trusts, and the Complete Avoidance of State Income Taxation'
Is Federalization Of Charity Law All Bad? What States Can Learn From The Internal Revenue Code,
2014
Benjamin N. Cardozo School of Law
Is Federalization Of Charity Law All Bad? What States Can Learn From The Internal Revenue Code, Melanie B. Leslie
Articles
No abstract provided.
Structuring And Restructuring Deals In 2014 (And Beyond),
2014
William & Mary Law School
Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen
William & Mary Annual Tax Conference
No abstract provided.
The Contemporary Tax Journal Volume 4, No. 1 – Fall 2014,
2014
San Jose State University
The Contemporary Tax Journal Volume 4, No. 1 – Fall 2014
The Contemporary Tax Journal
No abstract provided.
Reflections On The 'New Wave' Inversions And Notice 2014-52,
2014
University of Michigan Law School
Reflections On The 'New Wave' Inversions And Notice 2014-52, Reuven S. Avi-Yonah
Articles
On September 22 the Treasury Department issued Notice 2014-52, 2014-42 IRB 1. The notice was intended to fulfill President Obama’s pledge to use executive actions to the extent possible to block the new wave of corporate inversions. To what extent can the notice succeed? This article argues that while the notice is a useful first step, it is unlikely to stem the tide of inversion transactions. To do that, legislative action is needed in the short term. In the longer term, the only solution to inversions is coordination with other OECD countries in the context of the base erosion and …
Integrating Subchapters K And S And Beyond,
2014
University of Baltimore School of Law
Integrating Subchapters K And S And Beyond, Walter D. Schwidetzky
All Faculty Scholarship
This Article builds upon a similar, lengthier effort that I published in the Tax Lawyer in 2009. While there is overlap, this Article contains much new material. Important case law and tax proposals from the House Ways and Means Committee have come out in the interim. Due to space limitations, unlike my Tax Lawyer effort, this Article attempts to avoid prolixity. It assumes the reader has good knowledge of both Subchapters S and K and the tax entity selection process. If you are not that reader, a review of my Tax Lawyer article or Professor Mann's article in this symposium …
Formulary Appointment In The U.S. International Income Tax System: Putting Lipstick On A Pig?,
2014
J. Reuben Clark Law School, Brigham Young University
Formulary Appointment In The U.S. International Income Tax System: Putting Lipstick On A Pig?, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay
Michigan Journal of International Law
An affiliated corporate group consists of two or more corporations linked by sufficient stock ownership to cause them to function as an economic unit instead of as independent economic actors. Thus, an affiliated corporate group engaged in international business is often referred to as a multinational enterprise (MNE), a term that we will use throughout this Article. When corporate members of an MNE engage in transactions among themselves, the prices they employ (transfer prices) will significantly affect the amount of overall MNE income that is allocated to each member and, hence, to the tax bases of the various countries in …
Revenue, U.S. Government,
2014
Purdue University
Revenue, U.S. Government, Bert Chapman
Libraries Faculty and Staff Scholarship and Research
Provides a historical overview of U.S. Government revenue receipts and spending during the early years of national history. Presents revenue generation statistics, information on revenue sources, and information on domestic and international political and economic factors affecting government revenue receipts.
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax,
2014
Pace University
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham
Pace Law Review
In order to promote both equality and efficiency, this Comment proposes that individuals should have the opportunity to file jointly for tax and bankruptcy purposes when they have a relationship predicated upon economic interdependence, as opposed to basing the opportunity to file jointly upon marital status. Part I of this Comment will briefly discuss the history of marriage in the United States. In particular, Part I will discuss the role that the government has had in promoting and regulating marriage and how the treatment of married persons operates to the exclusion of the unmarried. Parts II and III of this …
Federal Taxation,
2014
Mercer University School of Law
Federal Taxation, Robert Beard
Mercer Law Review
In 2013, several interesting federal tax cases were decided in the United States Court of Appeals for the Eleventh Circuit and in the United States Tax Court with decisions appealable to the Eleventh Circuit. These cases addressed the scope of the Internal Revenue Code (I.R.C.) § 83, the economic performance rules, and ownership of tax refunds in bankruptcy.
Personal Service Versus Royalty Income For Athletes,
2014
San Jose State University
Personal Service Versus Royalty Income For Athletes, Chanpheareak (Luis) Chim
The Contemporary Tax Journal
No abstract provided.
Tax Incentives To Move Jobs Back To The U.S.,
2014
San Jose State University
Tax Incentives To Move Jobs Back To The U.S., Gamaliel Salazar
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal Volume 3, No. 2 – Spring 2014,
2014
San Jose State University
The Contemporary Tax Journal Volume 3, No. 2 – Spring 2014
The Contemporary Tax Journal
No abstract provided.
Tax Credit For Qualified Plug-In Electric Drive Motor Vehicle Purchases,
2014
San Jose State University
Tax Credit For Qualified Plug-In Electric Drive Motor Vehicle Purchases, Kara Virji-Gaidhar
The Contemporary Tax Journal
No abstract provided.
Reasoned Explanation And Irs Adjudication,
2014
Florida State University College of Law
Reasoned Explanation And Irs Adjudication, Steve R. Johnson
Scholarly Publications
Under the Administrative Procedure Act (APA), an administrative action can be invalidated as arbitrary and capricious if the agency fails to sufficiently explain the reasons for its choices. This principle applies to agency adjudication as well as to agency rulemaking. How does this principle apply to IRS adjudications? Examining five paradigms of IRS decisionmaking, this Article first establishes that the IRS does engage in APA–style adjudication. The Article then examines tax-specific explanation requirements and asks whether a more robust explanation duty patterned on the APA should be imposed on IRS determinations. Based on a variety of legal and prudential considerations, …
The Affordable Care Act And Its Impact On The Professional Tax Preparation Market In Kingsport, Tennessee,
2014
East Tennessee State University
The Affordable Care Act And Its Impact On The Professional Tax Preparation Market In Kingsport, Tennessee, Robert S. Forney Jr.
Undergraduate Honors Theses
The objective of this study is to test whether the Affordable Care Act will have an effect on the professional tax preparation industry of Kingsport, Tennessee. To accomplish this objective, the researcher collected surveys concerning taxpayers’ initial reaction to the realization that the law affects their 1040. A two proportion test for equality was performed and failed to reject the idea that the ACA will have an effect on the tax preparation industry of Kingsport. Because this study failed to prove that the change in legislation causes a jump in clientele for the professional tax preparation market, the fight for …
The Contemporary Tax Journal’S Interview Of Pam Olson,
2014
San Jose State University
The Contemporary Tax Journal’S Interview Of Pam Olson, Stuti Seth
The Contemporary Tax Journal
No abstract provided.
