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Wash Sales with Replacement by Related Parties

Calvin Johnson
In a realization system, taxpayers have an incentive to sell loss property from a diversified portfolio and hold gain property. With no limitations on selective loss sales, the effective tax rate on an...
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Taxing Shared Economies of Scale

Bradley T. Borden
ABSTRACT Economies of scale exist if long-run average costs decline as output rises. All else being equal, the decline in average costs should lead to greater profitability, making economies of scale...
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Impose Capital Gain Tax on Like-Kind Exchanges

Calvin Johnson
Current law allows a taxpayer to avoid taxation of gain on a disposition of real estate to the extent the taxpayer is willing to acquire other real estate as a replacement. The proposal would repeal section...
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Developing an International Tax Policy Strategy for NAFTA Countries

Arthur J. Cockfield
On January 1, 1994, Canada, the United States, and Mexico formed the North American Free Trade Agreement to promote their economic interests by lowering barriers to international trade and investment....
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Dealing with tax debts in bankruptcy after the BAPCPA

Burton J. Haynes
The intended beneficiaries of the humorously titled "Bankruptcy Abuse Prevention and Consumer Protection Act of 2005" (BAPCPA) were the big banks and credit card companies -- lobbying pays. The new law...
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Tax collection problems of military personnel

Burton J. Haynes
Many people with tax collection problems feel like they're in a combat zone, besieged by battalions of battle-hardened IRS Revenue Officers. But many tax practitioners, particularly those of us here in...
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The Meaning of Enterprise, Business, and Business Profits Under Tax Treaties and Domestic Tax Law (forthcoming, 2011)

Allison Christians
Written by: Allison Christians and Yariv Brauner[*] PART I. THE MEANING OF “ENTERPRISE” AND “BUSINESS” IN DOMESTIC NON-TAX LAW The terms ―business‖ and ―enterprise‖ are very widely...
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Managing California’s Fiscal Roller Coaster

David Gamage
When Proposition 13 passed in 1978, many commentators predicted disaster for California's state and local finances. Now, 30 years later, California is experiencing severe fiscal instability and a round...
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Gilmore v. United States: The Divorce

Joel Newman
Don and Dixie Gilmore divorced in 1955. He deducted 80 percent of his $40,000 in legal expenses because they were connected to his business. He claimed: (1) if Dixie had won, she would have taken over...
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A Proposal To Adopt Formulary Apportionment For Corporate Income Taxation: The Hamilton Project

REUVEN S. AVI-YONAH KIMBERLY A. CLAUSING I. Introduction[1] The current system of taxing the income of multinational firms in the United States is flawed across multiple dimensions. The system...
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