Recently added articles from Virginia Tax Review:
Taxing the consumption of capital gains.
Jan 01, 2009; ... This piece traces the history of the capital gain concept, and then the policy arguments for a lower rate on capital gains, to argue for an express requirement that the lower rate for capital gains be available only if the gains are reinvested. Consumed capital gain, the Article argues, is ...
On discounted partnership interests and adequate consideration.
Jan 01, 2009; ... <Pre> TABLE OF CONTENTS 1.INTRODUCTION 533A. Background on Application of Section 2036 in the 537 Family Limited Partnership ContextB. Rise of Adequate and Full Consideration542 ...
Taxing the financial income of multinational enterprises by employing a hybrid formulary and arm's length allocation method.
Jan 01, 2009; ... <Pre> TABLE OF CONTENTS I INTRODUCTION 690 II. THE ISSUE IN CONTEXT: WHY IS FORMULARY ALLOCATION626 OF MNES' FINANCIAL INCOME DESIRABLEA. How MNEs Utilize Related Party Financial 627 Transactions to ...
"Sit down and count the cost": a framework for constitutionally enforcing the 501(c)(3) campaign intervention ban.
Jan 01, 2009; ... ABSTRACT Section 501 (c)(3) of the Internal Revenue Code (Code) prohibits charities from intervening in a political campaign for or against a candidate for public office. The Internal Revenue Service (Service) currently interprets the campaign-intervention ban to absolutely ...
Real taxation of virtual commerce.
Jan 01, 2009; ... In virtual worlds, people participate in fantasy adventures or socialize in visually immersive online environments. Popular examples include World of Warcraft, Second Life, Entropia Universe, and Ultima Online. As more people are reportedly earning real money through their virtual-world ...
Comment on Yin, reforming the taxation of foreign direct investment by U.S. taxpayers.
Sep 22, 2008; ... In this excellent article, George Yin addresses an important proposal by the President's Advisory Panel on Federal Tax Reform. The Advisory Panel proposed that the United States should permanently switch from taxing the parent corporation of U.S. multinationals on worldwide income to a ...
A blueprint for tax reform and health reform.
Sep 22, 2008; ... <Pre> TABLE OF CONTENTS I.INTRODUCTION 288 II. ACTION-FORCING Events290A Expiration of Bush Tax Cuts291B. AMT ...
Comment on Leonard E. Burman, "a blueprint for tax reform and health reform".(response to article by Leonard E. Burman in this issue, p. 287)
Sep 22, 2008; ... <Pre> TABLE OF CONTENTS I. THE NEED FOR REFORM 326 A. The No-Reform Path: Deficits and Higher Marginal Tax 326 Rates B. Long-Term Fiscal Realities328 C. Barman's Proposal ...
Is the corporate tax system "broken"?
Sep 22, 2008; ... <Pre> TABLE OF CONTENTS I.INTRODUCTION 341 II. DECLINE OF THE CORPORATE TAX 343 A. Long-Term Decline 343 B. Role of Corporate Tax 344 C. Economic ...
The empty promise of estate tax repeal.
Sep 22, 2008; ... <Pre> TABLE OF CONTENTS IINTRODUCTION 369 II RHETORIC OF REPEAL 371 III Politics of Repeal 373 IV Between Repeal and Reform 381 VConclusion 388 </Pre> I. INTRODUCTION For more than eighty years, the ...
Transfer tax reform after EGTRRA-2001: reconstruction or further deconstruction?(Economic Growth and Tax Relief Reconciliation Act of 2001)
Sep 22, 2008; ... <Pre> TABLE OF CONTENTS I.INTRODUCTIONA. The Estate Planners392 B. The Agency 394 C. The Taxpayers 398 II. Issues in Reconstruction ...
The corporation as administrative agency: tax expenditures and institutional design.
Sep 22, 2008; ... Tax expenditure analysis asserts that an income tax system is a poor vehicle for implementing non-tax goals. The traditional analysis argues that government subsidies now available through tax deductions, tax credits, and the like should be converted into direct government expenditures ...