Federal Taxes on Gratuitous Transfers
Federal Taxes on Gratuitous Transfers

Author: Joseph M. Dodge

Publisher: Aspen Publishing

Published: 2014-12-09

Total Pages: 679

ISBN-13: 1454860421

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This book deals with the federal income tax as it bears on gratuitous transfers and with the federal wealth transfer taxes. The federal wealth transfer taxes presently consist of a partially unified estate and gift tax and a generation-skipping tax. The federal transfer tax system is separate and apart from the federal income tax. Features: Emphasis on text, statutes, and regulations, rather than cases (especially cases that involve routine application of law to facts) "Building block" organization (simple to complex estates), rather than segmented organization according to Code sections. Extensive use of questions and problems to aid students High-profile authorship in Joseph M. Dodge (a highly regarded tax specialist), Wendy C. Gerzog, and Bridget J. Crawford (both well-established in the field) The book reconstitutes the Estate and Gift tax course from the ground up in light of modern estates practice. For example, special valuation rules are treated as basic, as opposed to being just "tacked on" as other books treat them. More emphasis on valuation and use of FLPs than in other books. Valuation is introduced early on and integrated with other material Integration of related income tax materials, including income taxation of estates and trusts Relation of tax doctrine to tax planning strategies Focus on doctrine that influences the practice of estate and trust law, rather than doctrine for its own sake Reference to state law (including recent developments) as it bears on transfer tax issues, with full coverage of issues raised by community property systems

The Logic of the Transfer Taxes
The Logic of the Transfer Taxes

Author: Laura Cunningham

Publisher: West Academic Publishing

Published: 2020-12-29

Total Pages: 253

ISBN-13: 9781647081133

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The Logic of the Transfer Taxes: A Guide to the Federal Taxation of Wealth Transfers offers a broad survey of the federal transfer tax system. It thoroughly covers all of the fundamental rules of the gift, estate and generation skipping transfer taxes and provides numerous illustrative examples. It also offers a glimpse of some popular tax planning techniques, including FLPs, GRATS and IDGT'S, and the Special Valuation Rules of Chapter 14. It is appropriate for use as a coursebook for a two or three credit JD or LLM course, or as a reference for newcomers to the area. The Second Edition incorporates changes to the law made by the Tax Cuts and Jobs Act of 2017.

Transfer Pricing and the Arm's Length Principle in International Tax Law
Transfer Pricing and the Arm's Length Principle in International Tax Law

Author: Jens Wittendorff

Publisher: Kluwer Law International B.V.

Published: 2010-01-01

Total Pages: 914

ISBN-13: 9041132708

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The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.

Fundamentals of International Transfer Pricing in Law and Economics
Fundamentals of International Transfer Pricing in Law and Economics

Author: Wolfgang Schön

Publisher: Springer Science & Business Media

Published: 2012-02-15

Total Pages: 308

ISBN-13: 3642259804

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The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.

A Theory of Property
A Theory of Property

Author: Stephen R. Munzer

Publisher: Cambridge University Press

Published: 1990-01-26

Total Pages: 504

ISBN-13: 1316583473

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This book represents a major new statement on the issue of property rights. It argues for the justification of some rights of private property while showing why unequal distributions of private property are indefensible. Three features of the book are especially salient: it offers a challenging new pluralist theory of justification; the argument integrates perceptive analyses of the great classical theorists Aristotle, Locke, Hegel and Marx with a discussion of contemporary philosophers such as Nozick and Rawls; and the author moves with assurance among philosophy, law and economics to present a very broad, interdisciplinary study.

Understanding Estate and Gift Taxation
Understanding Estate and Gift Taxation

Author: Brant J. Hellwig

Publisher: Carolina Academic Press LLC

Published: 2019

Total Pages: 0

ISBN-13: 9781531012182

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Understanding Estate and Gift Taxation is designed primarily for use by law students taking a course on the United States transfer tax system, i.e., a course on the estate, gift, and generation-skipping transfer taxes. The book consists of 26 chapters, each addressing one of the basic topics typically covered in a course on the transfer tax system, including the computation of estate, gift, and generation-skipping transfer taxes; the gift tax annual exclusion; the estate and gift tax marital deductions; and the estate and gift tax implications of transfers with retained powers or interests. Because the Internal Revenue Code and Treasury Regulations are the primary source materials for the transfer tax system, the book includes numerous excerpts of those provisions. Each chapter also includes summaries of the leading cases and IRS rulings, plus examples of how this area of the law applies to common fact patterns. Understanding Estate and Gift Taxation is designed primarily for law students, but it is also intended to be useful to practitioners, including generalists who need a relatively brief summary of an estate and gift tax topic, beginning lawyers who intend to specialize in estate and gift taxation and estate planning, and experienced lawyers who wish to expand their practices into estate and gift taxation and estate planning. The book similarly would be useful to accountants who practice in these areas.

A Good Tax
A Good Tax

Author: Joan Youngman

Publisher:

Published: 2016

Total Pages: 260

ISBN-13: 9781558443426

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In A Good Tax, tax expert Joan Youngman skillfully considers how to improve the operation of the property tax and supply the information that is often missing in public debate. She analyzes the legal, administrative, and political challenges to the property tax in the United States and offers recommendations for its improvement. The book is accessibly written for policy analysts and public officials who are dealing with specific property tax issues and for those concerned with property tax issues in general.