In Part IV, Dean Marsan examines FATCA withholding liability for withholdable payments under Code Secs. 1471 and 1472, and provides a nine-point analysis - each of which must be answered affirmatively for the new 30-percent withholding tax to apply

Part IV examines FATCA withholding liability for withholdable payments under Code Secs. 1471 and 1472, and provides a nine-point analysis—each of which must be answered affirmatively for the new 30-percent withholding tax to apply

Should taxpayers finance government entry into an increasingly competitive, but technologically volatile, business market? The city of Philadelphia has just released a blueprint to provide a taxpayer-backed city-wide wi-fi service, under the rationale that broadband should be treated as a vital...

The plan announced last week in Philadelphia to create a government-owned wireless broadband network isn't needed, is economically and technologically unsound and will put the city's taxpayers at great financial risk. The Wireless Philadelphia Business Plan promises (1) ubiquitous broadband...

This chapter provides an accessible overview of our previous work on the impact of the abolition of the Rule Against Perpetuities (RAP) on trust fund situs. The implementation of the Generation Skipping Transfer (GST) Tax by the Tax Reform Act of 1986 sparked a movement to repeal the RAP. Since...

This Essay sketches some of the long-term economic and political consequences of making Washington D.C. the 51st State. The statehood debate has overwhelmingly focused on the same set of issues: the impact of statehood on the federal government’s structure. But if D.C. becomes a state, the...

This Article presents the first empirical study of the domestic jurisdictional competition for trust funds. To allow donors to exploit a loophole in the federal estate tax, since 1986 a host of states have abolished the Rule Against Perpetuities as applied to interests in trust. To allow...

In this Article, we provide a summary of recent developments impacting Connecticut estate planning and probate practice. In Part I, we provide a survey of selected 2008 case law relevant to the field. In Part II, we discuss several significant estate planning and administration complications...

While the use of tax amnesty programs has been commonplace for decades among both states and local governments, historically these offers have rarely been extended to delinquent real property taxes. In the last 10 years, however, there have been 26 property tax amnesties offered by local...

El ICIO es un impuesto muy controvertido por diversos motivos que van desde cuál sea su verdadera naturaleza, pasando por su «descendencia» de la tasa por licencia de obras y por atentar contra el principio de igualdad, hasta la concurrencia del mismo con varios tributos. Se han escrito ríos...