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3,037 full-text articles. Page 62 of 81.

Structuring And Restructuring Deals In 2014 (And Beyond), Stephen L. Owen 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.


Is Federalization Of Charity Law All Bad? What States Can Learn From The Internal Revenue Code, Melanie B. Leslie 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.


Pro And Con (Law): Considering The Irrevocable Nongrantor Trust Technique, Alyssa A. DiRusso 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'


Reflections On The 'New Wave' Inversions And Notice 2014-52, Reuven S. Avi-Yonah 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, Walter D. Schwidetzky 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?, J. Clifton Fleming Jr., Robert J. Peroni, Stephen E. Shay 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, Bert Chapman 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, Heather V. Graham 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, Robert Beard 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, Chanpheareak (Luis) Chim 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., Gamaliel Salazar 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, Kara Virji-Gaidhar 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.


The Affordable Care Act And Its Impact On The Professional Tax Preparation Market In Kingsport, Tennessee, Robert S. Forney Jr. 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 …


Reasoned Explanation And Irs Adjudication, Steve R. Johnson 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 Contemporary Tax Journal’S Interview Of Pam Olson, Stuti Seth 2014 San Jose State University

The Contemporary Tax Journal’S Interview Of Pam Olson, Stuti Seth

The Contemporary Tax Journal

No abstract provided.


Income Or Liability: How Casinos' Classification Of Outstanding Chips Determine Taxability, John Bulloch 2014 University of Nevada, Las Vegas -- William S. Boyd School of Law

Income Or Liability: How Casinos' Classification Of Outstanding Chips Determine Taxability, John Bulloch

UNLV Gaming Law Journal

No abstract provided.


Complicity And Collection: Religious Freedom And Tax, Jennifer Carr 2014 University of Nevada, Las Vegas -- William S. Boyd School of Law

Complicity And Collection: Religious Freedom And Tax, Jennifer Carr

Scholarly Works

This Article focuses on how the Religious Freedom Peace Tax Fund Bill might be improved so that members of Congress enact it. The bill would allow war tax resisters who qualify as pacifists to direct their tax money to a separate fund not to be used for military spending. At present, the IRS is expending time and resources trying to track down tax resisters, which results in loss of revenue for the government. This Article argues that passage of an amended version of the Religious Freedom Peace Tax Fund Bill would eliminate the tension between the IRS and war tax …


Federalism And Phantom Economic Rights In Nfib V. Sibelius, Matthew Lindsay 2014 University of Baltimore School of Law

Federalism And Phantom Economic Rights In Nfib V. Sibelius, Matthew Lindsay

All Faculty Scholarship

Few predicted that the constitutional fate of the Patient Protection and Affordable Care Act would turn on Congress’ power to lay and collect taxes. Yet in NFIB v. Sebelius, the Supreme Court upheld the centerpiece of the Act — the minimum coverage provision (MCP), commonly known as the “individual mandate” — as a tax. The unexpected basis of the Court’s holding has deflected attention from what may prove to be the decision’s more constitutionally consequential feature: that a majority of the Court agreed that Congress lacked authority under the Commerce Clause to penalize people who decline to purchase health insurance. …


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