An overview of the legislative history and case law development of the qualified conservation donation under IRC Section 170(h), also known as the conservation easement or facade easement tax deduction

It comes as no surprise to any observant person in this country that there is a wide disparity in our federal income tax treatment of persons who have differing incomes and financial resources. But while much has been written on tax law complexity and inefficiency, little or nothing has been...

This Article critically examines the efficiency of the quid pro quo test and its need for an exception in order to conform to the purpose of the charitable deduction; acting as a subsidy to those organizations the government feels provides a community benefit. Throughout the country,...

The Congressional testimony provides a framework for thinking about the role of the charitable deduction in the federal income tax. As changes to the deduction are weighed by policymakers, it is important to consider: (1) the existing characteristics and policy tenets of the charitable...

This article recommends allowing a lessor and a lessee to decide between themselves which party will be entitled to the tax benefit associated with the ownership of the leased property. It describes why the current linkage of tax benefits to property ownership is economically inefficient and...

There are two principal rationales for the charitable deduction. Depending upon choice of rationale, some tax reform changes are suggested and others are not. A base measurement rationale suggests eliminating the deduction for unrealized appreciation, keeping the benefit as a deduction and not a...

The Aloha State has been on the front line of justice for decades, including tax justice. This is the story of a two-decade-plus journey of the Hawaii earned income tax credit — including how the state might better serve financially challenged residents as they navigate the global pandemic’s...

This essay, scheduled to appear in the 2014 symposium issue of the Chapman Law Review, proposes enactment of a deduction to individuals for distributions received on stock in regular, or "C," corporations when the distributions are reinvested prior to the return date for the year of...