This article analyzes the Tax Court case of Garcia v. Commissioner. The article focuses on two key aspects of Garcia: (1) the classification of an athlete's endorsement income as royalty income rather than services income; and (2) the taxability of that royalty income under an "Artistes and...

This case deals with a Portuguese decision on the qualification of amounts due from image and economic rights of football players.The football industry involves billons of euro each year. Thus it is understandable that tax authorities have been paying increasing attention to the incomes of...

A tax system should be fair. According to conventional wisdom, this fairness mandate means that similarly situated taxpayers should pay similar taxes. Notably absent from most discussions about tax fairness or equity is any consideration of race. This makes sense, if one focuses on the tax...

Double taxation agreements pose a particular analytical problem. While they provide a coherent structure that encourages cross-border investment, the agreements also provide opportunities for taxpayers to avoid their domestic tax obligations. To prevent tax avoidance, some countries enact...

The business corporation, a central pillar of modern capitalism, is deemed to have a set of defining features that are universal across different jurisdictions and ever more widely available. However, a close examination of legal developments in Brazil, one of the world's largest economies,...

This Article examines the Establishment Clause's limitations on public funding using evangelical Christian college cases wherever possible. It purposely is designed as a primer for Christian college administrators who want to avoid constitutional challenges when seeking public funding. After a...