William A Drennan Copyright (c) 2012 All rights reserved. http://works.bepress.com/william_drennan Recent documents in William A Drennan en-us Mon, 13 Feb 2012 11:53:40 PST 3600 Surnamed Charitable Trusts: Immortality at Taxpayer Expense http://works.bepress.com/william_drennan/6 http://works.bepress.com/william_drennan/6 Wed, 24 Jun 2009 11:38:27 PDT Charitable trust law authorizes surnamed trusts, and provides no convenient mechanism to force a name change even hundreds of years after the founder's death. Tax law treats the use of a surname as harmless. A founder's ability to surname can provide a significant benefit to the founding family at the expense of the common good. This Article introduces the topic into the debate, provides new empirical evidence, and proposes a viable legislative response.

]]> William A. Drennan Taxation-Federal Income Strict Liability and Tax Penalties http://works.bepress.com/william_drennan/5 http://works.bepress.com/william_drennan/5 Wed, 24 Jun 2009 11:23:48 PDT This Article asserts that the current monetary penalty system fails to curb tax dodging because it is a fault-based, negligence style system, and any fault-based system would fail because of systemic features of our federal income tax. This Article proposes a new strict liability style penalty system, tempered by a graduated penalty rate and an exception for any nonfrivolous tax position conspicuously disclosed.

]]> William A. Drennan Taxation-Federal Income Einstein's Theory of Taxation http://works.bepress.com/william_drennan/4 http://works.bepress.com/william_drennan/4 Fri, 25 Apr 2008 08:55:35 PDT Albert Einstein said "the hardest thing in the world to understand is the income tax." The new nonqualified deferred compensation rules are a testament to Einstein's brilliance. The new rules will fail to achieve their statutory purpose, will create traps for the unwary, and should be repealed retroactively.

]]> William A. Drennan Taxation The Pirates Will Party On! The Nonqualified Deferred Compensation Rules Will Not Prevent CEOs from Acting Like Plundering Pirates and Should Be Scuttled http://works.bepress.com/william_drennan/3 http://works.bepress.com/william_drennan/3 Sun, 06 Apr 2008 14:32:29 PDT The government went off course when it attempted to stop outrageous CEO compensation schemes with new income tax rules on nonqualfied deferred compensation. IRC Section 409A should be scuttled.

]]> William A. Drennan Taxation Einstein's Theory of Taxation http://works.bepress.com/william_drennan/2 http://works.bepress.com/william_drennan/2 Sun, 30 Mar 2008 14:33:44 PDT Albert Einstein said "the hardest thing in the world to understand is the income tax." The new nonqualified deferred compensation rules are a testament to Einstein's brilliance. The new rules will fail to achieve their statutory purpose, will create traps for the unwary, and should be repealed retroactively.

]]> William A. Drennan Taxation-Federal Income The Pirates Will Party On! http://works.bepress.com/william_drennan/1 http://works.bepress.com/william_drennan/1 Sun, 30 Mar 2008 13:40:48 PDT The government went off course when it attempted to stop outrageous CEO compensation schemes with new income tax rules on nonqualified deferred compensation. IRC Section 409A should be scuttled.

]]> William A. Drennan Corporations Taxation-Federal Income