Articles

Taxation

Back to Basics: Rethinking Normative Principles in International Tax

International Tax is a relatively new legal system that lacks clear objectives and principles. These principles, which guide unilateral legislation and multilateral coordination, have not been discussed thoroughly through the lens of jurisprudence and legal philosophy. This Article offers a unique jurisprudential analysis of these normative principles by redefining them and clarifying several basic assumptions. ...

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Comments on Proposed Revenue Procedure in Notice 2019-07 Regarding Section 199A and Rental Real Estate Enterprises

Section 199A was added to the Code by An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018, commonly referred to as the Tax Cuts and Jobs Act. Final regulations under section 199A were issued on January 18, 2019. Notice 2019-07, issued simultaneously with the Final Regulations, contains a proposed revenue procedure detailing a proposed safe harbor...