Entity theory as myth in the origins of the corporate income tax.

From: William and Mary Law Review | Date: December 1, 2001| Author: Bank, Steven A. | Copyright information

INTRODUCTION

The United States has long operated under a dual system of business taxation in which corporations and partnerships receive disparate treatment. Corporations are treated as separate taxable entities, while partnerships are ignored for most purposes. Perhaps the most notable impact of such disparity is that income from businesses operating in corporate form is taxed twice--first at the corporate level when earned and a second time at the shareholder level whe...

Read all of this article with a FREE trial to HighBeam Research

Related newspaper, magazine, and journal articles from HighBeam Research

Entity theory as myth in the origins of the corporate income tax.
William and Mary Law Review ; INTRODUCTION The United States has long operated under a dual system of business taxation in which corporations and partnerships receive disparate treatment. Corporations are treated as separate taxable entities, while partnerships are ignored for most purposes. Perhaps the most notable impact of
Exploring the income tax treatment of borrowing and liabilities, or why the accrual method should be eliminated.
Virginia Tax Review ; ... the matching principle but took on a doctrinal life of its own as an independent tax rule. (148) That is the good news. The bad news is that it took about sixty years of case law, plus Congressional intervention, to re-fashion the all-events test ...
State income tax jurisdiction: a jurisprudential and policy perspective.
William and Mary Law Review ; ... Presence of employees, representatives or agents for purposes directly relating to the purchasing [sic] goods or services, gathering news and covering events, meeting with government officials, attending conferences, seminars and similar functions, and participating ...
What Has Tort Law Got To Do with It? Distinguishing Between Employees and Independent Contractors in the Federal Income Tax, Employment Insurance, and Canada Pension Plan Contexts
Canadian Tax Journal ; Precis La distinction entre employe et entrepreneur independant se retrouve dans plusieurs domaines du droit canadien. En depit des motifs administratifs differents qui justifient cette distinction, la legislation semble laisser entendre que le critere permettant de faire la distinction entre un
The superiority of an ideal consumption tax over an ideal income tax.
Stanford Law Review ; INTRODUCTION I. THE CORE ARGUMENT A. Basic Definitions and Relationships Between the Bases B. Arguments for an Income Tax C. The AS 1976 Argument--Efficiency D. The AS 1976 Argument--Redistribution II. RISK AND PROFITS III. WEALTH WITHOUT LABOR INCOME IV. SAVINGS HETEROGENEITY A. Rational Savings
THE INCOME TAX AND THE BURDEN OF PERFECTION
Northwestern University Law Review ; ... acknowledged. As early as 1943, Roswell Magill, then a professor of law at Columbia, summarized the situation: It will not be news to the taxpayers of the country to be told that the federal tax laws lack simplicity. Their complication, turgidity, and Alice-in-Wonder ...
The Federal Income Tax Act and Private Law in Canada: Complementarity, Dissociation, and Canadian Bijuralism
Canadian Tax Journal ; In order to apply the federal Income Tax Act (ITA), Canadian courts must first characterize the transactions and amounts to which different tax consequences apply. For this purpose, they have generally followed the rule laid down in the Duke of Westminster case that "the legal rights and
Your Money: Many happy (tax) returns! Two hundred years of income tax may not be everyone's idea of something to celebrate, yet 100 people a day are visiting the Revenue's birthday exhibition. Paul Slade reports
The Independent - London ; When it comes to those aspects of modern life worth celebrating, few people would raise a cheer for income tax. But now that the tax has reached its 200th birthday, the Inland Revenue is throwing a party. Despite its site in the mid-basement level of Somerset House, the Revenue's Bicentenary of
Income tax discrimination and the political and economic integration of Europe.(European Union)
Yale Law Journal ; ... nationality, and restriction to other cases in which cross-border income is taxed more heavily than domestic income. This distinction maps roughly, but not exactly, onto our distinction between discrimination against foreign producers (incoming investment) and foreign ... H.C. Luja, Tax Treaties and State Aid: Some ...
REPUBLICAN MAILING SAYS LOCKE WANTS INCOME TAX SENATE CANDIDATE CALLS THE CLAIM `WILDLY MISLEADING'.(News)
Seattle Post-Intelligencer (Seattle, WA) ; Despite Gov. Gary Locke's campaign pledge two years ago never to support an income tax as governor, a new mailing by the state Republican Party boldly asserts that he will revive the unpopular issue if Democrats win control of the state Senate. ``Stop Gary Locke's income tax. Vote Republican urges