Andrews & Kurth Centennial Professor of Law, University of Texas at Austin - School of Law, USA

8 years
Ain’t Charity: Disallowing Deductions for Kept Resources

The two proposals in this article have a common theme: Accounting for taxable income should reflect money a taxpayer has kept for his own self-serving uses. A charitable deduction is reasonable when t...

8 years
UBIT to the Defense! ESOPs and Government Entities

Calvin H. Johnson Ellen P. Aprill The unrelated trade or unrelated business income tax imposes tax on the unrelated business income of tax exempt organizations, including charities and pension p...

8 years
Wash Sales with Replacement by Related Parties

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 a...

8 years
Fixing Capital Gains at the Core

Eligibility for the lower capital gains tax rate is now broader than it should be. Capital gains originally meant amounts that were credited to the capital or corpus account. Capital gains were still ...

8 years
Elephant in the Parlor: Repeal of Stepup in Basis at Death

This proposal would end the step-up in basis for property acquired by reason of the death of another individual and increase the tax on inherited property when it is sold. The exemption for built-in g...

8 years
Deferred Payment Sales

Deferred Payment Sales: Change The Basis and Character Rules In installment sales and open transactions, tax is deferred until payments are received. This proposal would continue to defer tax until...

8 years
End Identification of Stock Certificates

This proposal would end the ability of taxpayers under current law to identify which lot of stock they have sold. The proposal would instead minimize unrealized appreciation and bring adjusted basis f...

8 years
Two Years of the Shelf Project

A. The Impending Tax Crisis The Congressional Budget Office estimates that the federal budget deficit for 2009 will total $1.6 trillion, or 11.2 percent of GDP.[1] Over the coming decade, federal s...

8 years
No Deductions for Tax Planning And Controversy Costs

Tax planning and tax litigation are too profitable for the taxpayer. The tax accounting for tax planning and controversy work allows an exemption for the reduction in tax achieved by the costs and als...

8 years
Amended Returns – Imposing a Duty to Correct Material Mistakes

T. Keith Fogg The amended return proposal would require a taxpayer to file an amended return to correct an innocent factual error large enough to be worth correcting once the error is discovered. F...

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