Volume 13, Number 2



Cost Sharing Agreements at Arms-Length: Altera Should be Reversed by the Ninth Circuit

by Brad Hemmer

On July 24th, 2018, the Internal Revenues Services (IRS) scored a huge victory against American companies, specifically tech companies, using cost sharing agreements with foreign subsidiaries to reduce their tax liability in the United States. The three-judge Ninth Circuit panel ruled in favor of the IRS 2-1 in Altera Corp. & Subsidiaries v. Commissioner, reversing the tax court. The victory was short-lived, however...


Net Neutrality Enforcement is Necessary to Provide Small Businesses With The Opportunity for Fair Competition

by Jonathan Wygonski

Wendy is an upstart entrepreneur, with an idea for a unique specialty product- the widget. She begins by selling the product online, through Amazon and Etsy, as a passion project in her spare time on weekends and after her full-time job. Sales start slow, but after a few months, she begins to see an uptick in orders. Soon, Wendy realizes that she can make a full-fledged career out of selling her product, so she decides to create an actual business. She searches “how to start my own company,” and in a Saturday afternoon, she incorporates her new company—Wendy’s Widgets, LLC—online...


Go Big and Go Home, Transformational Mixed-Use Developments and the Efficacy of Ohio House Bill 469

by Dustin W. Meeks

In February 2018, Ohio State Representative Thomas Patton (R-Strongsville) and State Senator Kirk Schuring (R-Canton) introduced Ohio House Bill 469 (H.B. 469).1 The bill proposes the creation of a tax credit against Ohio’s insurance premiums tax valued at ten percent of the development costs of a “transformational mixed-use development.” The proposal was inspired by a development project proposed in downtown Cleveland, Ohio which would qualify for the credit ....


When #AD is #BAD: Why the FTC Must Reform Its Enrichment of Disclosure Policy in the Digital Age

by Vanessa Chan

You’re on your fifth daily scroll through your Facebook newsfeed when a Buzzfeed article suddenly catches your eye. Underneath a photo of some colorful, minimalistic gadgets reads: “29 Cheap Things That’ll Make You Look Fancier Than You Really Are.” Intrigued, you click the article, which is organized just like any other Buzzfeed article, listing the novelty items and tools with photos and witty captions in an easy-to-read format. There are links to purchase...


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