Fred B. Brown

University of Baltimore - School of Law

Professor and Director of the Graduate Tax Program

1420 N. Charles Street

Baltimore, MD 21218

United States

  • University of Baltimore - School of Law

SCHOLARLY PAPERS

12

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Top 34,662

in Total Papers Downloads

2,531

SSRN CITATIONS

4

CROSSREF CITATIONS

2

Scholarly Papers (12)

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1.

Federal Income Taxation of U.S. Branches of Foreign Corporations: Separate Entity or Separate Rules?

Tax Law Review, Vol. 49, No. 1, 1993
Number of pages: 76 Posted: 20 Dec 2007 Last Revised: 06 Jan 2008
Fred B. Brown
University of Baltimore - School of Law
Downloads 804 (53,674)

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tax, international tax, effectively connected income

2.

Determining the Character of Section 357(c) Gain

Tax Lawyer, Vol. 62, No. 1, 2008
Number of pages: 58 Posted: 22 Mar 2009
Fred B. Brown
University of Baltimore - School of Law
Downloads 620 (75,303)

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3.

An Equity-Based, Multilateral Approach for Sourcing Income Among Nations

Florida Tax Review, Vol. 11, No. 7, 2011
Number of pages: 86 Posted: 10 Apr 2011 Last Revised: 20 Oct 2011
Fred B. Brown
University of Baltimore - School of Law
Downloads 237 (221,474)

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taxation, international taxation, source of income

4.

Wither FIRPTA?

Tax Lawyer, Vol. 57, No. 2, 2004
Number of pages: 48 Posted: 21 Dec 2007 Last Revised: 06 Jan 2008
Fred B. Brown
University of Baltimore - School of Law
Downloads 148 (336,615)

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tax, international tax, FIRPTA

5.

'Complete' Accrual Taxation

San Diego Law Review, Vol. 33, No. 4, 1996
Number of pages: 122 Posted: 09 May 2008 Last Revised: 14 Sep 2008
Fred B. Brown
University of Baltimore - School of Law
Downloads 141 (349,854)
Citation 3

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income taxation, artificial intelligence, valuation

6.

Tax Treatment of Legal Fees Under 2017 Tax Cuts and Jobs Act

Maryland Bar Journal, Volume 1, Issue 3, pp. 31-32 (2019)
Number of pages: 2 Posted: 01 Dec 2019
Fred B. Brown
University of Baltimore - School of Law
Downloads 131 (370,239)

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tax, deductions, legal expenses, miscellaneous itemized deductions, alternative minimum tax

7.

Reforming the Branch Profits Tax to Advance Neutrality

Virginia Tax Review, Vol. 25, No. 4, 2006
Number of pages: 76 Posted: 17 Dec 2007 Last Revised: 06 Jan 2008
Fred B. Brown
University of Baltimore - School of Law
Downloads 114 (410,501)

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8.

Should the Federal Government Help States and Local Governments Pay for Police Misconduct Through Tax-Exempt Bonds?

Virginia Tax Review, Forthcoming, University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 28 Posted: 30 Sep 2022 Last Revised: 04 May 2023
Fred B. Brown
University of Baltimore - School of Law
Downloads 73 (546,335)

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federal income taxation, tax-exempt bonds, police misconduct, tort law, constitutional law, 1983 claims

9.

Designing Nonrecognition Rules Under the Internal Revenue Code

24 Florida Tax Review 424 (2021), University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 98 Posted: 08 Jun 2021 Last Revised: 07 Nov 2022
Fred B. Brown
University of Baltimore - School of Law
Downloads 70 (559,019)

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income tax, realization, recognition, nonrecognition, valuation, liquidity, efficiency, equity, corporate taxation

10.

Proposing a Single, Simpler Test for Cash Equivalency

Tax Lawyer, Vol. 71, No. 3, 2018
Number of pages: 44 Posted: 28 Jun 2018
Fred B. Brown
University of Baltimore - School of Law
Downloads 69 (563,317)

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tax, tax accounting, cash method, cash equivalency

11.

Permitting Abused Spouses to Claim the Earned Income Tax Credit in Separate Returns

William & Mary Journal of Women and the Law, Vol. 22, No. 3, 2016
Number of pages: 42 Posted: 13 Jun 2016 Last Revised: 19 Jun 2016
Fred B. Brown
University of Baltimore - School of Law
Downloads 66 (576,733)

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tax, earned income tax credit, domestic abuse

12.

Proposal to Reform the Like Kind and Involuntary Conversion Rules In Light of Fundamental Tax Policies: A Simpler, More Rational and More Unified Approach

Missouri Law Review, Vol. 67, No. 4, 2002
Number of pages: 70 Posted: 21 Dec 2007
Fred B. Brown
University of Baltimore - School of Law
Downloads 58 (615,209)

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tax, nonrecognition, like kind exchange, involuntary conversion