Taxation Nationwide Uniformity and the Common Law of Federal Taxation Jasper L. Cummings, Jr. This Article presents a set of principal contentions about the creation of federal common law and then applies those contentions to a current issue in federal taxation. ...
Taxation A Simpler Debt-Equity Test Thomas D. Greenaway & Michelle L. Marion It is usually a straightforward tax question: Is an advance of capital to a business debt or equity? But in some cases the question gets harder to answer, mostly because of the tangled multifactor test we use. ...
Taxation Treaty Consistency Stephen B. Land Taxpayers can generally claim treaty benefits in some contexts, while using domestic law in other contexts, in each case choosing to apply the treaty or domestic law, whichever is more favorable. ...
Taxation A GAAP Critic’s Guide to Corporate Income Taxes Mark J. Cowan The basic framework for accounting for income taxes under generally accepted accounting principles (GAAP) has been in place for nearly 20 years. ...
Taxation Sometimes That Cadillac Is a Lemon: Why the High-Cost Health Insurance Excise Tax Needs a Tune-Up Before Implementation Eleanor Hagan Efforts to achieve national health coverage in the United States have been longstanding, elusive, and contentious. For more than 80 years, reformers have attempted to expand access to health services...
Taxation Fitting a Square Peg in a Round Hole: Calloway v. Commissioner’s Analytical Shortcomings Caroline Owens Van Wagoner Certain property transactions, particularly those involving the exchange of securities, are not always obvious taxable dispositions. The Tax Court and Eleventh Circuit recently faced such a problem...
The Tax Lawyer The Tax Lawyer, the nation’s premier, peer-reviewed tax law journal, is published quarterly as a service to its members by the American Bar Association Section of Taxation. Abstracts can be viewed by anyone, but full text pdfs are accessible only to members of the Section. Section members may also view the Spring 2018 issue of The Tax Lawyer in its entirety.
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