Since 2008, the world has been submerged in a severe and complex systemic crisis that has been affecting innumerable countries and challenging governments and economists from all over the planet to find solutions to deal with its devastating effects on the global economy. Reactions to the crisis range from trends pushed by multilateral organizations, such [...]
Full Story »Posted in Articles | Tagged International Taxation, issues, policy | Leave a response
Executive Summary State governments have had to make tough budget choices in recent years. Tax revenues have stagnated as a result of the poor economy, and that has prompted governors to take a variety of fiscal actions to close large budget gaps. Some governors have cut spending to balance their budgets, while others have pursued [...]
Full Story »Posted in Articles | Tagged fiscal policy, Governors | Leave a response
In every era and area of law you find a never-ending battle between two groups of legal thinkers: formalists and functionalists. Each is connected to long-standing and honorable traditions in Anglo-American jurisprudence. The formalists tend toward the law side of those traditions the search for order and certainty and the functionalists tend toward the equity [...]
Full Story »Posted in Articles | Tagged formalists, functionalists, income, IRS, taxpayers | Leave a response
In March 2004 the European Commission solicited comments on a proposal to simplify value added tax (VAT) obligations through a one-stop scheme.[1] The proposal was modest in scope. It was designed to build upon the success of a similar scheme[2] that dealt with non-EU established persons supplying digital products to non-taxable EU persons.[3] That scheme [...]
Posted in Articles | Tagged consumption, RST, tax problems, vat | Leave a response
Co-author: Todd D. Keator[*] TABLE OF CONTENTS I.INTRODUCTION II.DEVIATIONS FROM THE REVENUE PROCEDURE A.Common Deviations 1.Deemed Consent 3.Investor Loans 4.Sponsor Guarantees 5.Sponsor Bridge Loans B.Significant Deviations 1.Multiple Properties 2.Non-Pro Rata Debt 3.Construction Activities 4.Sponsor-Retained Interests III.REVERSE EXCHANGES INVOLVING TIC INTERESTs A.Securities Issues B.Contractual Issues C.Lender Approval IV.CONCLUSION I.INTRODUCTION Tenancy-in-common (“TIC”) investments offer investors the ability to [...]
Posted in Articles | Tagged Exchanges, Offerings, Reverse, TIC | Leave a response
This shelf project proposal covers several expenditures that are allowed as expenses as soon as they are incurred under current law but should be treated as capital expenditures. Given the treatment of debt financing, capitalization is needed to prevent negative tax or subsidy for investments, many with dubious merit. The expensing subsidy allows projects to [...]
Posted in Articles | Tagged capital, capitalization, expenditures, investments | Leave a response
A common trust fund (CTF) is a fund maintained by a bank exclusively for the collective investment of the funds of trust clients. Under section 584 of the code, a CTF pays no tax, but each participant must include its proportionate share of income and losses computed at the CTF level, even if the common [...]
Posted in Articles | Tagged common trust fund, distributions, income, Trust Funds | Leave a response
I have a confession: I can’t spell. Not that you can tell from my columns, where I successfully hide behind the spell-check function and the good efforts of Tax Analysts’ editors. How bad am I? Well, in sixth grade I won the English prize, but instead of the usual plaque, they gave me a dictionary. [...]
Posted in Articles | Tagged assessment, fraud, Limitation Period, tax return | Leave a response
Create Your Account - Free Updates