All Articles tagged tax

• Technology
  May 30, 2023 EDT
  A New Economic Frontier and Ohio’s Old Tax: Analyzing the Taxability of NFTs Under Ohio’s Sales and Use Tax
  Ian Dollenmayer

  This note explores the tax treatment of NFTs and proposes an addition to Ohio's current Streamlined Sales and Use Tax Agreement to ensure Ohio captures NFTs sales under this statute.

• Tax
  November 08, 2022 EDT
  Social Justice & Multi-Jurisdictional Tax: A Critical Examination of the Digitization of Commerce, Multi-Jurisdictional Tax & An Opportunity to Correct a Systemic Preference to Protect Wealth
  Natasha N. Varyani

  This article explores the effect of taxing the digital economy - specifically advertising - and how the revenue could be used to bring about social justice changes.

• Tax
  August 31, 2020 EDT
  Non-Cooperative Compliance in the Corporate Tax Audit
  Bret N. Bogenschneider

  A revised theory of the corporate tax audit is developed here based on non-cooperative audit practices.

  Abstract
• Tax
  August 31, 2020 EDT
  Tax Treaty Overrides and Friendliness Towards International Law: A Comparative Approach to Put the Later-in-Time Rule to the Test
  Nicolas M. Traut

  The piece advocates for a deference towards international law and provides a starting point for a reconsideration of the later-in-time-rule in the tax context of the United States.

  Abstract
• Tax
  August 31, 2020 EDT
  Qualified Opportunity Zones - How Active Participation and Complementary Legislation Can Help States Develop Their Distressed Communities
  Michael Neiman

  This article explores the creation of the Opportunity Zone law, explains how to structure an Opportunity Zone investment, and details the benefits available to taxpayers taking advantage of Opportunity Zones.

  Abstract
• Tax
  May 22, 2019 EDT
  Transfer Pricing Through §482–Looking Beyond Amazon v. Commissioner and other MNEs when Transferring Preexisting Intangibles under the Pre-2009 CSA Regulations
  Avery Moore

  The need for the Service to control the transfer pricing market will continue to grow as MNEs find other ways to use transfer pricing strategies to avoid certain U.S. taxes.

  Abstract
• Tax
  September 08, 2018 EDT
  Section 831(b) Captive Insurance Companies: Why Policymakers have it all Wrong
  Drew D. Estes

  In spite of the continuous underperformance following the 2008-09 financial crisis, the captive insurance industry is among the brightest spots within the economy.

  Abstract