| Author | Title | Citation | Summary | Year |
| Michael B. Cohen |
AVOIDING DOUBLE TAXATION AND EXPATRIATION: A COMPREHENSIVE SOLUTION TO FATCA AND CORPORATE INVERSION |
41 North Carolina Journal of International Law 595 (Spring, 2016) |
I. Introduction: A Scenario. 596 II. FATCA. 604 A. Background of Global Citizenship Taxation. 604 B. Double Taxation and Its Solutions: Exclusions, Foreign Tax Credits, and Income Tax Treaties. 607 1. Foreign Tax Credits. 607 2. Section 911 Exclusions. 609 3. Income Tax Treaties. 610 C. The Necessity, Enactment, and Effects of FATCA. 611 1. Why Was... |
2016 |
| Chad G. Marzen |
BANKRUPTCY AND FEDERAL CROP INSURANCE |
34 Virginia Environmental Law Journal 328 (2016) |
I. Introduction. 328 II. Liens on Future Crops--Indubitable Equivalent of Cash Collateral and Adequate Protection of Security Interests Issue. 331 III. Alleged Misrepresentations Concerning Crop Insurance Applications. 335 IV. Crop Insurance Premiums and Setoffs Under the Bankruptcy Code. 337 V. Federal Crop Insurance Act Statute of Limitations.... |
2016 |
| Andrew B. Dawson |
BETTER THAN BANKRUPTCY? |
69 Rutgers University Law Review 137 (Fall, 2016) |
According to many in the bankruptcy field, small business debtors are increasingly turning to state debtor-creditors laws as an alternative to federal bankruptcy relief. One particularly popular state law is the assignment for the benefit of creditors. The conventional wisdom is that these procedures provide a state law alternative to liquidate a... |
2016 |
| Xuan-Thao Nguyen , Jeffrey A. Maine |
BRANDING TAXATION |
50 Georgia Law Review 399 (Winter, 2016) |
Table of Contents I. Introduction. 401 II. The Branding Role in Business. 405 III. Protecting Brands Through Litigation. 410 A. TRADEMARK DILUTION. 410 B. TRADEMARK INFRINGEMENT. 413 C. UNFAIR COMPETITION. 416 D. TRADEMARK LITIGATION COSTS. 419 E. TRADE DRESS PROTECTION. 421 IV. Copyright Protection for Branding Content. 422 V. Tax Treatment of... |
2016 |
| Jonathan C. Lipson |
BRAUCHER'S BUSINESS: FORESEEING RELATIONAL CONTRACT BANKRUPTCY |
58 Arizona Law Review 173 (2016) |
Jean Braucher was a leading scholar of contract and consumer bankruptcy law. Although she did not devote substantial energy to corporate bankruptcy, an important but comparatively under-cited 1994 paper, Bankruptcy Reorganization and Economic Development (Economic Development) recognized that relationalism--and, by inference, relational... |
2016 |
| Kristin Niver |
CHANGING THE FACE OF URBAN AMERICA: ASSESSING THE LOW-INCOME HOUSING TAX CREDIT |
102 Virginia Law Review Online 48 (June, 2016) |
ON June 25, 2015, the U.S. Supreme Court held that Low-Income Housing Tax Credit (LIHTC) allocations could violate the Fair Housing Act (FHA) if used to perpetuate racially concentrated poverty. On the heels of this decision, on July 8, 2015, the U.S. Department of Housing and Urban Development (HUD) issued its final rule on the FHA's... |
2016 |
| Ruth Mason |
CITIZENSHIP TAXATION |
89 Southern California Law Review 169 (January, 2016) |
The United States is the only country that taxes its citizens' worldwide income, even when those citizens live indefinitely abroad. This Article critically evaluates the traditional equity, efficiency, and administrability arguments for taxing nonresident citizens. It also raises new concerns about citizenship taxation, including that it puts the... |
2016 |
| J. Clifton Fleming, Jr. , Robert J. Peroni , Stephen E. Shay |
DEFENDING WORLDWIDE TAXATION WITH A SHAREHOLDER-BASED DEFINITION OF CORPORATE RESIDENCE |
2016 Brigham Young University Law Review 1681 (2016) |
This Article argues that a principled, efficient, and practical definition of corporate residence is necessary even if some form of corporate integration is adopted, and that such a definition is a key element in designing either a real worldwide or a territorial income tax system as well as a potential restraint on the inversion phenomenon. The... |
2016 |
| Steven Specht |
DEVELOPING AN INTERNATIONAL CARBON TAX REGIME |
16 Sustainable Development Law & Policy 28 (Spring, 2016) |
As atmospheric CO2 remains in the range of 400 ppm, it is necessary to find new international coordination to deal with climate change. The best way forward is an international regime of harmonized domestic carbon taxes. By agreeing to a minimum amount of taxation on domestic, point-source producers, money can be set aside for adaptation costs and... |
2016 |
| Evelyn Brody , Marcus Owens |
EXILE TO MAIN STREET: THE I.R.S.'S DIMINISHED ROLE IN OVERSEEING TAX-EXEMPT ORGANIZATIONS |
91 Chicago-Kent Law Review 859 (2016) |
The Chicago-Kent conference on charity oversight took place on Day 924 of the TaxProf blog's IRS Scandal --Day 1 being the Friday two-and-a-half years ago that the U.S. Internal Revenue Service's Lois Lerner apologized for inappropriate use of Tea Party and other names in selecting applicants for Internal Revenue Code § 501(c)(4) status for... |
2016 |
| Martha T. Mccluskey |
FRAMING MIDDLE-CLASS INSECURITY: TAX AND THE IDEOLOGY OF UNEQUAL ECONOMIC GROWTH |
84 Fordham Law Review 2699 (May, 2016) |
Tax law has helped make struggle, risk, and sacrifice the new normal for the American middle class. This change in middle-class status results not only from tax policies, but also from ideas about tax that cultivate acquiescence in unequal austerity. As Lisa Philipps shows in the context of Canada, recent income tax policies encourage middle-class... |
2016 |
| C. Hudson Cheshire |
FROM BOB JONES TO OBERGEFELL: WHAT THE HISTORY OF THE GAY RIGHTS MOVEMENT MEANS FOR THE FUTURE OF RELIGIOUS TAX-EXEMPTION |
40 Law & Psychology Review 383 (2015-2016) |
In 2015, in Obergefell v. Hodges, the U.S. Supreme Court found a constitutional right to same-sex marriage. Though it was a decisive victory for champions of LGBT rights, this decision re-affirmed a growing anxiety among many proponents of religious freedom. While many religious people oppose the perceived moral back-step of gay marriage, even in... |
2016 |
| Iris H-Y Chiu |
FROM MULTILATERAL TO UNILATERAL LINES OF ATTACK: THE SUSTAINABILITY OF OFFSHORE TAX HAVENS AND FINANCIAL CENTRES IN THE INTERNATIONAL LEGAL ORDER |
31 Connecticut Journal of International Law 163 (Spring, 2016) |
Introduction. 165 I. The Economic Model of Micro-states. 165 II. From Multilateral Approaches to Unilateral Approaches Against the Economic Models of Micro-states. 171 A. Driving Factors for Unilateral Approaches against Micro-states-Changes in the Political Economy of Finance and Post-Global Financial Crisis Reforms.. 173 III. Key Aspects of Tax... |
2016 |
| |
Husky International Electronics, Inc. v. Ritz: Implications of the Supreme Court's Expansive Interpretation of the "Actual Fraud" Prong of Bankruptcy Code Section 523(a)(2)(A) |
25 Norton Journal of Bankruptcy Law and Practice 4 (December 1, 2016) |
Gregory Fox is associate in Goodwin Proctor LLP'S Financial Industry and Financial Restructuring practices. |
2016 |
| Linda Sugin |
INVISIBLE TAXPAYERS |
69 Tax Law Review 617 (Summer, 2016) |
Only the little people pay taxes. So said Leona Helmsley to her maid. That maid is one of millions of other little people who are largely anonymous in the legal regime that regulates taxation. They pay their bills without taking advantage of avoidance schemes, tax planning, or discretionary administrative largesse. They are legally invisible,... |
2016 |
| Steve R. Johnson |
IS AN AMERICAN VALUE ADDED TAX INEVITABLE? |
15 Florida State University Business Review 1 (Spring, 2016) |
I. Introduction. 1 II. Our Hybrid Income Tax. 4 A. Administrability-Based Deviations from Pure Income Taxation. 5 B. Consumption-Based Deviations. 6 C. Non-Tax Policy-Based Deviations. 7 III. Strengths and Weaknesses of the Hybrid Tax. 8 A. Strengths. 9 1. Revenue. 9 2. Known Quantity Economically and Socially. 9 B. Uniqueness (or Lack Thereof)... |
2016 |
| Jared F. Knight |
IS TAX INCREMENT FINANCING RACIST? CHICAGO'S RACIALLY DISPARATE TIF SPENDING |
101 Iowa Law Review 1681 (May, 2016) |
Tax Increment Financing (TIF) is a financing tool used by cities large and small across the country. Chicago, whose history includes several instances of de jure and de facto racial discrimination, is an especially prolific TIF user. This Note examines TIF distribution in each of Chicago's 50 wards. Both a regression analysis and full... |
2016 |
| Moon J. Koo |
IS THE INVESTMENT TAX CREDIT REALLY MORE COERCIVE THAN THE PERSONAL PROPERTY TAX EXEMPTION IN THE CUNO CONTROVERSY? |
69 Tax Lawyer 817 (Summer, 2016) |
This Article reviews the Sixth Circuit's approach in Cuno v. DaimlerChrsyler in determining whether a state-level investment tax incentive is coercive and therefore unconstitutional under the Dormant Commerce Clause, and argues that the court should look at diversifying factors that could be decisive on the date that a business decision was made to... |
2016 |
| Colin McGrath |
MUNICIPAL BANKRUPTCY AND THE LIMITS OF FEDERALISM |
18 University of Pennsylvania Journal of Constitutional Law 1265 (April, 2016) |
During the 2008 financial crisis, general municipalities across the United States began considering bankruptcy as a means for resolving systemic budget crises. This signified a substantial shift in the relationship between municipalities and Chapter 9 of the federal bankruptcy code. Until 2008, few general municipalities filed under Chapter 9.... |
2016 |
| |
NEW YORKERS SUBJECT TO 21 SEPARATE TAXES |
22 CITYLAW 40 (March/April, 2016) |
TThe New York City budget relies heavily on 21 separate taxes to fund its budget. The largest tax revenue source is real estate taxes and the smallest is horse race admissions. A lawyer in sole practice living and working in New York City and renting in a Manhattan office building will be hit by at least six different taxes: property, personal... |
2016 |
| Mary Ellen Wimberly |
NO STATE LEFT BEHIND: AN ANALYSIS OF THE POST-EGTRRA DEATH TAX LANDSCAPE AND AN ARGUMENT FOR KENTUCKY TO REPEAL STATE DEATH TAXES |
104 Kentucky Law Journal 525 (2015-2016) |
Wealth transfers are likely to surge as the baby boomer generation passes away over the next fifty-five years. For Americans wishing to pass on the maximum amount of their hard-earned wealth to selected beneficiaries, why die in Kentucky? At death, a Kentuckian's property is subject to the Kentucky inheritance tax when the property is passed to... |
2016 |
| Fred B. Brown |
PERMITTING ABUSED SPOUSES TO CLAIM THE EARNED INCOME TAX CREDIT IN SEPARATE RETURNS |
22 William and Mary Journal of Women and the Law 453 (Spring, 2016) |
Introduction I. The Earned Income Tax Credit A. Overview of the EITC B. The Married Filing Separately Prohibition of Claiming the EITC II. Difficulties Faced by Individuals Subjected to Domestic Abuse in Claiming EITCs A. Possible Undesirability of Filing a Joint Return with an Abusive Spouse B. Feasibility of Filing as Single or Head of Household... |
2016 |
| |
PROPERTY TAX CASE DISMISSED |
22 CITYLAW 131 (November/December, 2016) |
Tenant alleged that the City's allocation of the property tax burden violated due process and equal protection. Ernest Robinson sought declaratory and injunctive relief alleging that the City's property tax classification system created a disparate and adverse impact on African-American and Hispanic residents, deprived them of due process and equal... |
2016 |
| Tina Xu |
STAYING IN HOLLYWOOD AND THE BIG APPLE: THE EFFECTIVENESS AND DESIGN OF FILM PRODUCTION TAX CREDITS IN NEW YORK AND CALIFORNIA |
2016 Columbia Business Law Review 426 (2016) |
Film production tax credits have become an increasingly common feature of the state tax system. These tax credit programs were originally a response to worries about runaway production of films to foreign jurisdictions offering similar incentives. Now, even states with a historical comparative advantage in film production and strong in-state... |
2016 |
| Ira K. Lindsay |
TAX FAIRNESS BY CONVENTION: A DEFENSE OF HORIZONTAL EQUITY |
19 Florida Tax Review 79 (2016) |
Horizontal equity is the principle that people who earn equal income should owe equal tax. It has gotten a bad name. Although horizontal equity remains a textbook criterion of tax fairness, scholarly literature is largely hostile. Scholars ranging from the legal theorist Louis Kaplow to philosophers Thomas Nagel and Liam Murphy question its... |
2016 |
| Courtney Lauren Anderson |
TAXATION AND REPRESENTATION: A HEALTHY SUPPLEMENT TO PPACA |
10 Charleston Law Review 1 (Spring 2016) |
I. 2 II. INTRODUCTION. 5 III. PART I: COMMUNITY ECONOMIC DEVELOPMENT AND INITIATIVES TO CREATE HEALTH EQUITY. 12 A. Community Economic Development. 12 B. Health Disparities. 15 IV. PART II: HEALTH EQUITY DEVELOPMENT: FORMALIZING THE COMMUNITY ECONOMIC DEVELOPMENT AND HEALTH EQUITY RELATIONSHIP. 20 A. The Simultaneous Creation of Economic... |
2016 |
| Ari Glogower |
TAXING CAPITAL APPRECIATION |
70 Tax Law Review 111 (Fall, 2016) |
The realization rule--which defers tax on asset gains and losses until a disposition --has been blamed for the most serious abuses, inequities, and complications found in the law. The rule skews investment behavior, is responsible for much of the Code's complexity, and distorts the taxation of corporations and capital gains. Most critically, the... |
2016 |
| Samuel D. Brunson |
TAXING UTOPIA |
47 Seton Hall Law Review 137 (2016) |
Nineteenth-century American religious movements challenged many aspects of American society. Although their challenges to mainstream America's vision of sex and marriage remain the best-known aspects of many of these groups, their challenges to traditional American economics are just as important. Eschewing individual ownership of property, many of... |
2016 |
| C. Garrison Lepow |
TEENAGERS, TWENTY SOMETHINGS, AND TAX INEQUALITY: A PROPOSAL TO SIMPLIFY THE AGE REQUIREMENTS OF THE DEPENDENCY EXEMPTION |
19 NYU Journal of Legislation and Public Policy 797 (2016) |
The dependency exemption affects close to forty-eight million individual tax returns nationwide. Like many other tax provisions, the child's age is the factor most likely to disqualify families. Generally, parents qualify for the dependency exemption if their child is eighteen years or younger. This benefit is extended for children up to age... |
2016 |
| Bobby L. Dexter |
THE HATE EXCLUSION: MORAL TAX EQUITY FOR DAMAGES RECEIVED ON ACCOUNT OF RACE, SEX, OR SEXUAL ORIENTATION DISCRIMINATION |
13 Pittsburgh Tax Review 197 (Spring, 2016) |
Scholars on both sides of the reparations literature divide commonly contemplate some form of federal monetary outlay. At the same time, given both the absence of such an outlay and the dire prognosis that such largesse is forthcoming, tax scholars rarely contribute to traditional reparations literature. With this Article, Professor Dexter... |
2016 |
| David C. Elkins |
THE MERITS OF TAX COMPETITION IN A GLOBALIZED ECONOMY |
91 Indiana Law Journal 905 (Spring, 2016) |
Since the turn of the current century, leading transnational organizations and academic scholarship have identified tax competition among countries as one of the scourges of the international tax regime. Both the EU and the OECD have warned that tax competition erodes the tax bases of Member States and impedes their ability to provide essential... |
2016 |
| Lily Kahng |
THE NOT-SO-MERRY WIVES OF WINDSOR: THE TAXATION OF WOMEN IN SAME-SEX MARRIAGES |
101 Cornell Law Review 325 (January, 2016) |
In United States v. Windsor, the Supreme Court invalidated the Defense of Marriage Act definition of marriage as between one man and one woman, heralding its subsequent recognition, in Obergefell v. Hodges, of a constitutional right to same-sex marriage. Windsor cleared the way for same-sex couples to be treated as married under federal tax laws,... |
2016 |
| Richard Gershon |
THE SOCIO-ECONOMICS OF THE FEDERAL ESTATE TAX: WHY DO SO MANY PEOPLE HATE (OR LOVE) THIS CENTENARIAN? |
49 Akron Law Review 329 (2016) |
I. Introduction. 329 II. The Estate Tax: A Visceral Reaction by Some and Support From Others. 330 A. The Current Estate Tax Limits. 331 B. Surprising Haters of the Estate Tax. 333 1. The Truth About Family Farms and Businesses. 334 2. The Truth About Double Taxation . 335 C. Self-Interested Lovers of the Estate Tax. 335 D. The Best Socio-Economic... |
2016 |
| David Spencer |
THE U.N. TAX COMMITTEE, DEVELOPING COUNTRIES, AND CIVIL SOCIETY ORGANIZATIONS (PART 2) |
27 Journal of International Taxation 44 (January, 2016) |
Civil society organizations, in pushing developing countries to adopt formulary apportionment with unitary taxation, are leading them down the wrong road. Part 1 of this article ( 26 JOIT 42 (December 2015) discussed the efforts of the G77 and China, representing about 134 countries, to achieve an upgrade of the U.N. Committee of Experts on... |
2016 |
| Jonah Peppiatt |
THE WATERFALL OF TIERS: A RELOCATION COST-BASED THEORY OF MUNICIPAL INSOLVENCY AND A PROPOSAL FOR A NEW MUNICIPAL BANKRUPTCY REGIME |
32 Emory Bankruptcy Developments Journal 335 (2016) |
Existing chapter 9 literature has centered on the non-liquidation assumption--that municipal bankruptcy law exists to provide municipalities a breathing spell from creditors and disallows the liquidation of municipalities. This assumption rests on the notion that chapter 9 exists solely to help municipalities continue to provide essential... |
2016 |
| Jennifer Nwachukwu |
"COMMUNITY DEVELOPMENT vs. ECONOMIC DEVELOPMENT: RESIDENTIAL SEGREGATION, TAX CREDITS, AND THE LACK OF ECONOMIC DEVELOPMENT IN BALTIMORE'S BLACK NEIGHBORHOODS" |
5 University of Baltimore Journal of Land and Development 1 (Fall, 2015) |
In 1967, the National Advisory Commission on Civil Disorders penned one of the most famous statements about race in America: Our nation is moving toward two societies, one black, one white--separate and unequal. For the city of Baltimore, MD, that statement rings true even in 2013. Outsiders think of Baltimore through the lens of HBO's The Wire.... |
2015 |
| Linda Elizabeth Coco |
"FOAMING THE RUNWAY" FOR HOMEOWNERS: U.S. BANKRUPTCY COURTS "PRESERVING HOMEOWNERSHIP" IN THE WAKE OF THE HOME AFFORDABLE MODIFICATION PROGRAM |
23 American Bankruptcy Institute Law Review 421 (Summer, 2015) |
Most of our most precious rights and freedoms are a series of exceptions to an overall moral and legal framework that suggests we shouldn't really have them in the first place. Since 2008, Congress has enacted manifold legislation aimed at reversing the effects of a housing crisis, but each law has ultimately inured to the benefit of banks and... |
2015 |
| Matthew Akers |
A RACE TO THE BOTTOM? INTERNATIONAL INCOME TAX REGIMES' IMPACT ON THE MOVEMENT OF ATHLETIC TALENT |
17 University of Denver Sports and Entertainment Law Journal 11 (Spring, 2015) |
As the world has become increasingly global, so too have sports expanded on the international stage. While in the past, athletes may have rarely competed outside of their home countries with the exception of events such as the Olympic Games and world championships, athletes today routinely compete in a number of different countries throughout a... |
2015 |
| Timothy J. Tracey |
BOB JONESING: SAME-SEX MARRIAGE AND THE HANKERING TO STRIP RELIGIOUS INSTITUTIONS OF THEIR TAX-EXEMPT STATUS |
11 FIU Law Review 85 (Fall 2015) |
It is . . . it is going to be an issue. With those words, the Solicitor General of the United States, Donald B. Verrilli, Jr., announced that religious liberty is directly threatened by the legalization of same-sex marriage. General Verrilli represented the Obama Administration at the oral argument in Obergefell v. Hodges, the case concerning... |
2015 |
| Evgeny Magidenko |
CLASSIFYING FEDERAL TAXES FOR CONSTITUTIONAL PURPOSES |
45 University of Baltimore Law Review 57 (Fall 2015) |
In 2012, ruling on a challenge to President Obama's landmark healthcare legislation, the Supreme Court upheld the legislation's individual mandate penalty as a tax. The Court's decision relied in part on the finding that the penalty was not a direct tax and so its lack of apportionment was not fatal. This was the first Supreme Court case in decades... |
2015 |
| Tristan G. Axelrod |
DEFENDING STATE EXEMPTIONS IN BANKRUPTCY |
27 Loyola Consumer Law Review 284 (2015) |
Throughout the past century's cyclical battles for bankruptcy reform, legislators and scholars have debated the need for federal control over bankruptcy estate exemptions. Millionaire criminals and Wall Street hucksters shielding assets from creditors provide perennial fuel for the argument that bankruptcy exemptions inspire systemic abuse. Few... |
2015 |
| Jodie A. Kirshner |
DESIGN FLAWS IN THE BANKRUPTCY REGIME: LESSONS FROM THE U.K. FOR PREVENTING A RESURGENT CREDITORS' RACE IN THE U.S. |
17 University of Pennsylvania Journal of Business Law 527 (Winter 2015) |
A current trend in U.S. bankruptcy law reflects the predictions of economic theory related to common pool resources. According to the theory, without coordinating law to account for and distribute limited assets in an orderly way, creditors race to claim the assets for themselves. The winners of the race deprive other creditors of value and make... |
2015 |
| Daniel Tarantola |
EQUAL FOOTING: CORRECTING THE E-COMMERCE TAX HAVEN |
10 Brooklyn Journal of Corporate, Financial & Commercial Law 277 (Fall, 2015) |
Perhaps long ago a seller's physical presence was a sufficient part of a trade to condition the imposition of a tax on such presence. But in today's economy, physical presence frequently has very little to do with a transaction a State might seek to tax. The Internet has fundamentally changed the way businesses and consumers interact. Parties... |
2015 |
| Robert J. Landry, III , David W. Read |
EROSION OF ACCESS TO CONSUMER BANKRUPTCY'S "FRESH START" POLICY IN THE UNITED STATES: STATUTORY REFORMS NEEDED TO ENHANCE ACCESS TO JUSTICE AND PROMOTE SOCIAL JUSTICE |
7 William & Mary Policy Review 51 (Fall, 2015) |
There is limited ability of qualified debtors to access justice in the form of bankruptcy relief in the United States. One-third of bankruptcy filers are below the poverty level. In the words of one researcher, debtors are simply too broke to file. This paper explores issues of access to justice through the Chapter 7 bankruptcy proceeding in the... |
2015 |
| |
Et Tu, Ralph?: More on Motors Liquidation , and a Bonus on Attorney's Fees in Appeals of Involuntary Bankruptcies |
35 Bankruptcy Law Letter 1 (May 1, 2015) |
My good and respected friend, Professor Ralph Brubaker, makes some interesting points in responding to my February 2015 article on Motors Liquidation.[ ] On some of them, hes even right. On the whole though, while hes not quite wrong, hes never quite right either. Professor Brubakers basic point is that Article 9 of the Uniform Commercial Code... |
2015 |
| John O. Hayward |
EXOTIC DANCING: TAXABLE GYRATIONS OR EXEMPT ART? |
68 Tax Lawyer 739 (Summer, 2015) |
Although exotic dancers usually embroil themselves in censorship battles with local authorities, recently they have tussled with the Service over whether their dancing is subject to admission or entertainment taxes, or exempt as cultural or artistic performance. This Article examines several recent cases where exotic dancing was taxed, while... |
2015 |
| Jason Chang, Alan M. Long |
GENERAL PROVISIONS: AMEND CHAPTER 1 OF TITLE 33 OF THE OFFICIAL CODE OF GEORGIA ANNOTATED, RELATING TO GENERAL PROVISIONS REGARDING INSURANCE, SO AS TO ESTABLISH QUALIFIED LOW-INCOME COMMUNITY INVESTMENT; PROVIDE FOR A SHORT TITLE; PROVIDE FOR DEFINITIONS |
32 Georgia State University Law Review 177 (Fall, 2015) |
Code Sections: O.C.G.A. §§ 10-10-21 (new); 33-1-24 (new) Bill Number: HB 439 Act Number: N/A Veto Number: 2 Georgia Laws: N/A Summary: The bill would have created $55 million in new tax credits that could have been used by an insurance company and credited towards its state insurance premium tax liability for equity investments in low-income... |
2015 |
| J. Clifton Fleming, Jr. , Robert J. Peroni , Stephen E. Shay |
GETTING SERIOUS ABOUT CROSS-BORDER EARNINGS STRIPPING: ESTABLISHING AN ANALYTICAL FRAMEWORK |
93 North Carolina Law Review 673 (March, 2015) |
A multinational enterprise (MNE) may use cross-border earnings stripping as a tax planning strategy. This strategy involves a higher-tax affiliate making deductible payments to a low- or zero-tax affiliate to reduce the MNE's global effective tax rate and, in the process, erode the corporate tax bases of countries where its economic activity... |
2015 |
| Eric Rubin |
KNOWING AN "EDUCATIONAL INSTITUTION" WHEN YOU SEE ONE: APPLYING THE COMMERCIALITY APPROACH TO TAX EXEMPTIONS FOR UNIVERSITIES UNDER § 501(C)(3) |
92 Washington University Law Review 1055 (2015) |
Beginning with the earliest colonial schools, educational institutions have had a consistent presence in America, challenging both their students' intellects and the federal government, which must implement laws to define and monitor the roles of educational institutions. As colleges and universities have proliferated, particularly over the last... |
2015 |
| Michael David Williams |
LAND COSTS AS NON-ELIGIBLE BASIS: ARBITRARY RESTRICTIONS ON STATE POLICYMAKING AUTHORITY IN THE LOW-INCOME HOUSING TAX CREDIT PROGRAM |
18 NYU Journal of Legislation and Public Policy 335 (2015) |
Introduction. 336 I. The Location Decision. 339 A. Quantity Versus Quality. 339 B. The Importance of Neighborhood. 343 1. Education. 347 2. Health. 348 3. Economic Self-Sufficiency. 349 4. Public Safety. 350 II. Incentives in the Low-Income Housing Tax Credit Program. 351 A. The Low-Income Housing Tax Credit Program. 352 1. Applicable Fraction and... |
2015 |