3501 Sansom Street
Philadelphia, PA 19104
300 Conshohocken State Rd
West Conshohocken, PA 19428
University of Pennsylvania Law School
in Total Papers Downloads
State & federal taxation, Internet sales, taxing software in the cloud, hosting out-of-state servers, nexus, foreign income taxation, international transactions, income allocation among jurisdictions, defining a permanent establishment, collecting tax judgments in foreign court, int’l tax neutrality
Taxation, administrative law, administrative rules and regulations, Administrative Procedure Act, Treasury Regulation, judicial deference to IRS rulemaking, Chevron doctrine, Home Concrete, APA, Mayo Foundation
Taxation, administrative law, administrative rules and regulations, judicial deference to IRS rulemaking, IRS legislative regulations, IRS interpretive regulations, IRS rulings, retroactive rules, good cause exception
Income Taxation, State Income Tax, Arthur Laffer, Causation of Relative Decline in Gross State Product, Causation, Statistical Correlation, State Economies, State GDP
Taxation, Internal Revenue Code section 6662(h), section 6659, statutory interpretation, valuation, basis, overvaluation, penalties, tax shelters without economic substance
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