Suchergebnisse

The United States face enormous challenges in the energy area. Climate change, biofuels policy, energy security and environmental degradation are all intimately bound up with energy production and consumption. Historically, the federal government has relied on tax subsidies to effect energy policy. With mounting federal deficits, policymakers and advocates are increasingly calling for a rethinking of our energy tax policy. How can the federal tax code strengthen environmental policy and reduce security concerns in the area of energy? The authors tackle such difficult problems as climate change, efficient taxation of oil and gas, and optimal oil tax policy in a world with OPEC oil producers dominating world oil supply. This volume presents a number of innovative policy suggestions backed by sophisticated and cutting-edge research carried out by leading scholars in the area of energy taxation

In this article, the author considers the peculiarly preferred position of the tax lien under section 67 of the Bankruptcy Act. From his consideration of the position of the trustee and the claim of the government he concludes that the law as presently applied is inequitable. He advocates that the government's secret lien be held invalid against the trustee, that the inchoate lien doctrine should not be applied in bankruptcy, and that the doctrine of Moore v. Bay be modified.

In light of the recent Supreme Court holding in United States v. Bliss Dairy, Inc.10 that the tax benefit rule requires income recognition by a corporation when it distributes previously expensed assets in complete liquidation, this Note assesses the dubious continued vitality of the tax benefit rule's single taxpayer construct-that is, the requirement that the same individual or entity serve as both the deducting and the recovering taxpayer. As the following analysis indicates, expansion of the tax benefit rule into a multiple taxpayer construct potentially requires some form of "recapture" in numerous factual settings previously considered non-taxable under existing nonrecognition provisions. In response to the unpredictability of the Bliss 'Dairy analysis in any given non-recognition context and the pervasive recapture implications of either a liberal or literal interpretation of the Bliss Dairy holding,this Note suggests an alternative basis for decision under the Bliss Dairy facts. This alternative requires the use of section 446(b), which would allow the IRS to achieve the Bliss Dairy result without causing any distortion of the tax benefit rule's traditional scope, applicability, or function. This Note also recommends legislation that would define the exact scope of various nonrecognition provisions and that would provide, in the case of "tax benefit rule income" falling outside the scope of those provisions, a recognition scheme that enhances both the policy considerations behind the applicable nonrecognition provision and the corrective goals implicit in section 111.

This annual publication sites sections of South Carolina law pertaining to property tax. It includes names and addresses of county property tax assessors, definitions and citations, classification and valuation of property, assessment procedure, assessment practice by taxpayers and exemptions from taxation.