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, 2016 The paradigm tax dispute involves a taxpayer on one side and the government on the other. In that traditional dyad, only the taxpayer matters, even though the interrelatedness of taxpayers across the fiscal system means that the outcome of any one ...
Sugin, Linda
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The Death of Tax Court Exceptionalism [PDF]
SSRN Electronic Journal, 2014 Tax exceptionalism — the view that tax law does not have to play by the administrative law rules that govern the rest of the regulatory state — has come under attack in recent years. In 2011, the Supreme Court rejected such exceptionalism by holding that judicial review of the Treasury Department’s interpretations of the tax code is subject to the same
Hoffer, Stephanie R. +1 more
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, 2018 The Vienna Convention on the Law of Treaties (VCLT) contemplates the interpretation of treaties topic in its articles 31, 32 and 33, portraying the frame to be followed by one who is engaged in this difficult endeavor. Tax treaties are, fore and foremost,
Dalton Luiz Dallazem
semanticscholar +1 more source
Acta Iuris Stetinensis, 2023 The aim of this article is to analyse the most recent judgments of administrative courts concerning Article 70(6)(1) of the Tax Ordinance Act in order to determine how they will affect the application of this provision. It provides for the possibility to
Łukasz Pilarczyk
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A Test of Sovereignty: Franchise Tax Board of the State of California v. Gilbert P. Hyatt [PDF]
, 2019 In Franchise Tax Board of California v. Hyatt, the Supreme Court considers whether to overrule Nevada v. Hall, a 1979 Supreme Court decision. Hall permitted a State to be haled into the court of another State without its consent.
Dill, Timothy
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WPŁYW DYREKTYW I ROZPORZĄDZEŃ UNII EUROPEJSKIEJ NA POLSKIE PRAWO PODATKOWE
Zeszyty Prawnicze, 2016 The Impact of European Union Directives and Regulations on Polish Tax Law Summary The subject of this article are the methods used to align Polish tax regulations with EU law and the level of alignment achieved.
Rafał Bernat
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Cooperative Act in Brazil and governing tax legislation
Boletín de la Asociación Internacional de Derecho Cooperativo, 2021 The purpose of this article is to present the legal-normative regulation of the cooperative act in Brazil, with special association to the tax treatment it has been given based on the interpretations adopted by the superior courts of justice. Received:
Brasil do Pinhal Pereira Salomão +1 more
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Studies in Logic, Grammar and Rhetoric, 2013 This article refers to the issues associated with the crucial significance of the interpretation of tax law provisions made by administrative courts in the course of the judicial inspection of tax decisions, within the context of protecting the ...
Dumas Anna, Pietrasz Piotr
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Zatrudnienie funkcjonariuszy w administracji celno-skarbowej po reformie
Studia z Zakresu Prawa Pracy i Polityki Społecznej, 2021 Employment of officers in customs and tax administration after the reform The article presents the legal regulations concerning the officers of the former Customs Service adopted by the legislator ...
Elżbieta Ura
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Why a Wealth Tax is Definitely Constitutional [PDF]
, 2020 Wealth tax reform proposals are playing a major role in the 2020 presidential campaign. However, some opponents of these wealth tax reform proposals have claimed that a wealth tax would be unconstitutional. Other prominent critics have argued that wealth
Brooks, John R, Gamage, David
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