The Federalization Of The Duty Of Loyalty Governing Charity Fiduciaries Under United States Tax Law,
2011
University of Houston
The Federalization Of The Duty Of Loyalty Governing Charity Fiduciaries Under United States Tax Law, Johnny Rex Buckles
Kentucky Law Journal
No abstract provided.
Choking Out Local Community Service Organizations: Rising Federal Tax Regulation And Its Impact On Small Nonprofit Entities,
2011
Michigan State University
Choking Out Local Community Service Organizations: Rising Federal Tax Regulation And Its Impact On Small Nonprofit Entities, Nicole S. Dandridge
Kentucky Law Journal
No abstract provided.
Federal Regulation Of Nonprofit Board Independence: Focus On Independent Stakeholders As A "Middle Way",
2011
American University
Federal Regulation Of Nonprofit Board Independence: Focus On Independent Stakeholders As A "Middle Way", Benjamin Moses Leff
Kentucky Law Journal
No abstract provided.
The "Federalization" Problem And Nonprofit Self- Regulation: Some Initial Thoughts,
2011
University of Iowa
The "Federalization" Problem And Nonprofit Self- Regulation: Some Initial Thoughts, Mark Sidel
Kentucky Law Journal
No abstract provided.
The Stable American Mind: Understanding Attitudes Towards Government And Taxes, 1990-2011,
2011
Claremont McKenna College
The Stable American Mind: Understanding Attitudes Towards Government And Taxes, 1990-2011, Christopher P. Eldred
CMC Senior Theses
As the federal government seeks ways to stimulate our economy and reduce our national debt, understanding public attitudes on the role and size of government and the taxes that support it is important. This thesis evaluates how US public opinion towards government and taxes has changed from 1990 to the present, and analyzes several potential causes for changes that have occurred. It is intended to be an update of William G. Mayer’s 1992 book entitled The Changing American Mind, which analyzed changing public opinion from 1960-1988. In following his analysis, the causes I have analyzed are generational replacement, fiscal …
Doing Too Much: The Standard Deduction And The Conflict Between Progressivity And Simplification,
2011
Georgetown University Law Center
Doing Too Much: The Standard Deduction And The Conflict Between Progressivity And Simplification, John R. Brooks
Georgetown Law Faculty Publications and Other Works
In U.S. federal income tax, the standard deduction, along with the personal exemptions, provides taxpayers with a minimum amount of untaxed income, effectively creating a "zero bracket amount." For historical and political reasons, however, the standard deduction also operates as a simplified substitute for the itemized deductions, such as the deductions for extraordinary medical expenses, charitable contributions, and home mortgage interest. This seemingly reasonable compromise in fact leads to substantial, and surprising, conceptual complexity. In particular, close analysis of each of the two roles shows that their effects, and related criticisms, are often contradictory, which in turn makes it difficult, …
The Post-Tarp Movement To Regulate Banker Pay,
2011
William & Mary Law School
The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason
Faculty Publications
No abstract provided.
Exclusion From Income Of Compensation For Services And Pooling Of Labor Occurring In A Noncommercial Setting,
2011
University of Michigan Law School
Exclusion From Income Of Compensation For Services And Pooling Of Labor Occurring In A Noncommercial Setting, Douglas A. Kahn
Articles
When cash is received for services, it typically will constitute gross income to the recipient.' But what if the payments are made in a noncommercial setting such as the payment by a parent to a child for mowing the lawn or performing household chores? As discussed later in this Essay, there are reasons to conclude that such payments do not constitute income. The problem of how to treat receipts from a noncommercial activity frequently arises in the context of an exchange of services. A similar problem arises when services are provided by several persons pursuant to a pooling of labor …
Formulary Apportionment: Myths And Prospects - Promoting Better International Policy And Utilizing The Misunderstood And Under-Theorized Formulary Alternative,
2011
University of Michigan Law School
Formulary Apportionment: Myths And Prospects - Promoting Better International Policy And Utilizing The Misunderstood And Under-Theorized Formulary Alternative, Reuven S. Avi-Yonah, Ilan Benshalom
Articles
This article seeks to re-examine the formulary alternative to transfer pricing by inquiring whether partial integration of formulary concepts into current practices would offer a reasonable alternative to transfer pricing rules. We believe that the key to achieving an equitable and efficient allocation of MNE income is to solve the problem of the residual, i.e., how to allocate income generated from mobile assets and activities whose risks are borne collectively by the entire MNE group. These assets and activities generate most of the current transfer pricing compliance and administrative costs, as well as tax avoidance opportunities. A limited formulary tax …
The Case For Dividend Deduction,
2011
University of Michigan Law School
The Case For Dividend Deduction, Reuven S. Avi-Yonah, Amir C. Chenchinski
Articles
The December 2010 compromise between President Barack Obama and the Republicans extended the 15% tax rate on dividends through the end of 2012. At that point, however, the rate may revert to the Clinton administration rate-39.6%-or be raised to 20%-as proposed by the Obama Administration. Thus, the United States may either abandon corporate-shareholder integration, maintain partial integration, or perhaps even adopt the George W Bush administration's 2003 proposal to exempt dividends altogether-as advocated by some Republicans in Congress. Given this uncertainty and the likelihood of additional Congressional action, now may be a good time to revisit the integration issue. Another …
New Medicare Contribution Tax On Investment Income,
2011
San Jose State University
New Medicare Contribution Tax On Investment Income, Huan Jin
The Contemporary Tax Journal
No abstract provided.
Summaries From The 26th Annual Tei-Sjsu High Technology Tax Institute,
2011
San Jose State University
Summaries From The 26th Annual Tei-Sjsu High Technology Tax Institute, Ankit Mathur, Zhihua Cai, Tim Kelly, Marja Mirkovic, Sampada Deshmukh, Ami Shah
The Contemporary Tax Journal
No abstract provided.
Increasing The Gasoline Excise Tax,
2011
San Jose State University
Front Matter (Letter From The Editor, Welcome Message, Etc.),
2011
San Jose State University
Front Matter (Letter From The Editor, Welcome Message, Etc.), Ankit Mathur, Annette Nellen
The Contemporary Tax Journal
No abstract provided.
Too Close To Home: Limiting The Organizations Subsidized By The Charitable Deduction To Those In Economic Need,
2011
University of Washington School of Law
Too Close To Home: Limiting The Organizations Subsidized By The Charitable Deduction To Those In Economic Need, Shannon Weeks Mccormack
Articles
The charitable deduction allows taxpayers to deduct amounts donated to organizations pursuing statutorily designated purposes from their otherwise taxable income. By lowering the after-tax cost of giving and encouraging taxpayers to donate more than they otherwise would, the charitable deduction subsidizes a broad variety of organizations. Some of these organizations provide widespread societal benefits, while others provide narrower benefits that remain closer to the taxpayer-donor’s home. To evaluate these current laws, this Article focuses on efficiency criteria, which limit subsidized organizations to those with donor support that does not cover the costs needed to optimally provide goods and services. Existing …
Income Tax Discrimination: Still Stuck In The Labyrinth Of Impossibility,
2011
Columbia Law School
Income Tax Discrimination: Still Stuck In The Labyrinth Of Impossibility, Michael J. Graetz, Alvin C. Warren Jr.
Faculty Scholarship
In previous articles, we have argued that the European Court of Justice's reliance on nondiscrimination as the basis for its decisions did not (and could not) satisfy commonly accepted tax policy norms, such as fairness, administrability, economic efficiency, production of desired levels of revenues, avoidance of double taxation, fiscal policy goals, inter-nation equity, and so on. In addition, we argued that the court cannot achieve consistent and coherent results by requiring nondiscrimination in both origin and destination countries for transactions involving the tax systems of more than one member state. We demonstrated that – in the absence of harmonized income …
U.S. Defense Contracts During The Tax Expenditure Battles Of The 1980s,
2011
University of Michigan Law School
U.S. Defense Contracts During The Tax Expenditure Battles Of The 1980s, Susan J. Guthrie, James R. Hines Jr.
Articles
This paper considers the impact of the tax treatment of military contractors on the cost and timing of U.S. military procurement. Prior to the early 1980s, taxpayers were permitted to defer tax obligations on profits earned from long-term contracts. Legislation passed in 1982, 1986, and 1987 required that at least 70 percent of the profits earned on long-term contracts be taxed as accrued, thereby significantly reducing the tax benefits associated with long term contracting. Comparing contracts that were ineligible for these tax benefits with those that were eligible, it appears that between 1981–1989 the duration of U.S. Department of Defense …
Narrowing The Tax Gap Through Presumptive Taxation,
2011
University of Michigan Law School
Narrowing The Tax Gap Through Presumptive Taxation, Kyle D. Logue, Gustavo G. Vettori
Articles
Can the United States government significantly reduce the federal tax gap? This question has attracted a great deal of scholarly attention over the years and has been the focus of numerous government reports. The "tax gap" is the official term for the Treasury Department's estimate of the difference between what American taxpayers should pay to the federal government in a given tax year (that is, the amount of tax they owe, based on a reasonable interpretation of existing tax laws as applied to particular taxpayers' circumstances) and what they actually pay. This estimate is derived from painstaking and detailed audits …
The Loophole That Would Not Die: A Case Study In The Difficulty Of Greening The Internal Revenue Code,
2011
Duke Law School
The Loophole That Would Not Die: A Case Study In The Difficulty Of Greening The Internal Revenue Code, Lawrence A. Zelenak
Faculty Scholarship
Congress and the Treasury have commissioned the National Academy of Sciences (NAS) “to undertake a comprehensive review of the Internal Revenue Code of 1986 to identify the types of and specific tax provisions that have the largest effects on carbon and other greenhouse gas emissions and to estimate the magnitude of those effects.” The hope of the proponents of the NAS carbon audit is that Congress, once informed of the results of the audit, will respond by “greening” the Internal Revenue Code. This Essay cautions that a more environmentally friendly Code will not necessarily follow from the legislative consciousness-raising of …
The Internal Revenue Code And Latino Realities: A Critical Perspective,
2011
UC Hastings College of the Law
The Internal Revenue Code And Latino Realities: A Critical Perspective, Leo P. Martinez, Jennifer M. Martinez
Faculty Scholarship
No abstract provided.
