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In this article, McCoskey and Narotzki explain why the basis rules under section 358 require tweaking when, in exchange for stock, a transferor of property also receives an installment note with excess basis
Persistent link: https://www.econbiz.de/10014025905
In 2021, the OECD proposed new rules for the cross-border taxation of multinational corporations. The proposed rules set forth the most significant reform to international tax rules in several decades. They follow approximately a decade of multilateral negotiation led by the OECD and drafted by...
Persistent link: https://www.econbiz.de/10014025908
This article considers the tax consequences of a booster's contribution to a college athletics program, using the case study of financier Robert Burton's multi-million dollar contribution to the University of Connecticut football program. This article discusses the income and gift tax issues...
Persistent link: https://www.econbiz.de/10013119703
This article advances an exogenous-endogenous distinction for purposes of determining and calculating quid pro quos under section 170. This test holds that exogenous benefits — benefits that arise independently of, or arise outside of, the taxing authority — are properly considered quid pro...
Persistent link: https://www.econbiz.de/10012897785
Persistent link: https://www.econbiz.de/10012899391
While only several decades ago, the idea of corporate social responsibility was not trivial, it seems that most scholars today understand that corporations owe special commitments to their stakeholders which go beyond common regulatory and conventional requirements in promoting the community in...
Persistent link: https://www.econbiz.de/10014343698
Social data production is a unique form of value creation that characterizes informational capitalism. Social data production also presents critical challenges for the various legal regimes that are encountering it. This Article provides legal scholars and policymakers with the tools to...
Persistent link: https://www.econbiz.de/10014346400
The COVID-19 pandemic caused a sharp global economic decline. The U.S. government responded to the downturn with record fiscal legislation totaling over $5 trillion, which includes considerable tax relief. Most notably, the U.S. government distributed over $800 billion in three rounds of...
Persistent link: https://www.econbiz.de/10013215260
In this article, the authors review the income tax treatment of prizes and awards in the context of Dr. Ralph Steinman who died in 2011 before being named a Nobel Laureate in Medicine. The Nobel Committee has announced that it intends to pay the prize money to Dr. Steinman's estate. Should this...
Persistent link: https://www.econbiz.de/10013112326
This document is the web appendix for Optimal Tax Policy and the Symmetries of Ignorance (June 2011). University of Pennsylvania, Institute for Law & Economic Research Paper No. 11-19; U of Penn Law School, Public Law Research Paper No. 11-21. Available at SSRN: "http://ssrn.com/abstract=1856123"...
Persistent link: https://www.econbiz.de/10013113396