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Tax

Social Justice & Multi-Jurisdictional Tax: A Critical Examination of the Digitization of Commerce, Multi-Jurisdictional Tax & An Opportunity to Correct a Systemic Preference to Protect Wealth
November 08, 2022 EDT
Social Justice & Multi-Jurisdictional Tax: A Critical Examination of the Digitization of Commerce, Multi-Jurisdictional Tax & An Opportunity to Correct a Systemic Preference to Protect Wealth
Natasha N. Varyani

This article explores the effect of taxing the digital economy - specifically advertising - and how the revenue could be used to bring about social justice changes.

Federal Regulation of the Municipal Securities Market: Testing the Efficacy of the Political Process as a Tenth Amendment Limitation on Congress
May 11, 2021 EDT
Federal Regulation of the Municipal Securities Market: Testing the Efficacy of the Political Process as a Tenth Amendment Limitation on Congress
Aubrey Searcy

This comment attempts to answer the perplexing question of why the municipal securities market, a $3.8 trillion market, is largely exempt from regulation by the Securities and Exchange Commission.

Non-Cooperative Compliance in the Corporate Tax Audit
August 31, 2020 EDT
Non-Cooperative Compliance in the Corporate Tax Audit
Bret N. Bogenschneider

A revised theory of the corporate tax audit is developed here based on non-cooperative audit practices.

Tax Treaty Overrides and Friendliness Towards International Law: A Comparative Approach to Put the Later-in-Time Rule to the Test
August 31, 2020 EDT
Tax Treaty Overrides and Friendliness Towards International Law: A Comparative Approach to Put the Later-in-Time Rule to the Test
Nicolas M. Traut

The piece advocates for a deference towards international law and provides a starting point for a reconsideration of the later-in-time-rule in the tax context of the United States.

August 31, 2020 EDT
Qualified Opportunity Zones - How Active Participation and Complementary Legislation Can Help States Develop Their Distressed Communities
Michael Neiman

This article explores the creation of the Opportunity Zone law, explains how to structure an Opportunity Zone investment, and details the benefits available to taxpayers taking advantage of Opportunity Zones.

May 22, 2019 EDT
Transfer Pricing Through §482–Looking Beyond Amazon v. Commissioner and other MNEs when Transferring Preexisting Intangibles under the Pre-2009 CSA Regulations
Avery Moore

The need for the Service to control the transfer pricing market will continue to grow as MNEs find other ways to use transfer pricing strategies to avoid certain U.S. taxes.

Section 831(b) Captive Insurance Companies: Why Policymakers have it all Wrong
September 08, 2018 EDT
Section 831(b) Captive Insurance Companies: Why Policymakers have it all Wrong
Drew D. Estes

In spite of the continuous underperformance following the 2008-09 financial crisis, the captive insurance industry is among the brightest spots within the economy.