Virginia Tax Review articles

Recent articles from Virginia Tax Review

Taxing the consumption of capital gains.
January 1, 2009... This piece traces the history of the capital gain concept, and then the policy arguments for a lower rate on capital gains, to argue for an express requirement that the lower rate for capital gains be available only if the gains are reinvested. Consumed capital gain, the Article argues, is...

On discounted partnership interests and adequate consideration.
January 1, 2009... TABLE OF CONTENTS 1. INTRODUCTION 533 A. Background on Application of Section 2036 in the 537 Family Limited Partnership Context B. Rise of Adequate and Full Consideration 542 ...

Taxing the financial income of multinational enterprises by employing a hybrid formulary and arm's length allocation method.
January 1, 2009... TABLE OF CONTENTS I INTRODUCTION 690 II. THE ISSUE IN CONTEXT: WHY IS FORMULARY ALLOCATION 626 OF MNES' FINANCIAL INCOME DESIRABLE A. How MNEs Utilize Related Party Financial 627 Transactions to Avoid...

"Sit down and count the cost": a framework for constitutionally enforcing the 501(c)(3) campaign intervention ban.
January 1, 2009... ABSTRACT Section 501 (c)(3) of the Internal Revenue Code (Code) prohibits charities from intervening in a political campaign for or against a candidate for public office. The Internal Revenue Service (Service) currently interprets the campaign-intervention ban to absolutely prevent...

Real taxation of virtual commerce.
January 1, 2009... In virtual worlds, people participate in fantasy adventures or socialize in visually immersive online environments. Popular examples include World of Warcraft, Second Life, Entropia Universe, and Ultima Online. As more people are reportedly earning real money through their virtual-world...