EFFECTS of the TAX CUTS and JOBS ACT: a PRELIMINARY ANALYSIS William G
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TALES from the KPMG SKUNK WORKS: the BASIS-SHIFT OR DEFECTIVE-REDEMPTION SHELTER by Calvin H
(C) Tax Analysts 2005. All rights reserved. does not claim copyright in any public domain or third party content. TALES FROM THE KPMG SKUNK WORKS: THE BASIS-SHIFT OR DEFECTIVE-REDEMPTION SHELTER By Calvin H. Johnson Table of Contents Calvin H. Johnson is professor of law at the Uni- versity of Texas at Austin. This report arises out of his I. Was FLIP/OPIS Fair Game? ............433 testimony before the U.S. Senate Permanent Subcom- A. Description of the FLIP/OPIS Basis-Shift mittee on Investigation hearings on the role of profes- Shelter ........................ 433 sionals in the U.S. tax shelter industry. Prof. Johnson has agreed to serve as an expert for plaintiffs who B. The Heart of the Shelter ............ 435 bought KPMG shelters and seek recovery of costs. He C. The Paramount Substance-Over-Form thanks James Martens and Samuel Buell for comments Doctrines ....................... 438 on an earlier draft, but acknowledges responsibility II. FLIP/OPIS and Professional Standards ... 440 for errors. A. The One-in-Three Chance Test ........ 440 In this report, Johnson argues that the basis-shift or B. One-in-Three Applied to Outcomes .... 441 defective-redemption shelter, called FLIP or OPIS by III. Concluding Remarks ................ 442 KPMG, was an early product of KPMG’s endeavor to develop complete tax packages that could be sold for KPMG, the fourth largest accounting firm, is negoti- multimillion-dollar fees to many customers. The ating with the Justice Department over the terms by which it might avoid criminal indictment for its conduct FLIP/OPIS shelter gives a rare opportunity, he says, to 1 see both KPMG internal deliberations and also the arising out of its tax shelters. -
06Dem Internationalen Steuerwettbewerb Begegnen
DEM INTERNATIONALEN STEUERWETTBEWERB 06BEGEGNEN I. Motivation II. Der Tax Cuts and Jobs Act und seine Auswirkungen 1. Wesentliche Elemente der Steuerreform 2. Makroökonomische Auswirkungen der Steuerreform III. Deutschland im internationalen Steuerwettbewerb 1. Gewinnsteuersätze international im Abwärtstrend 2. Diskriminierende Besteuerung von mobilen und immobilen Aktivitäten IV. Herausforderungen bei der internationalen Besteuerung 1. Prinzipien zur Festlegung der Besteuerungsrechte 2. Besteuerung der Digitalwirtschaft als Herausforderung 3. Alternative Harmonisierungsbestrebungen V. Steuerpolitische Optionen zur Förderung privater Investitionen 1. Moderate Senkung der Steuerbelastung 2. Abbau von Verzerrungen Eine andere Meinung Literatur Dem internationalen Steuerwettbewerb begegnen – Kapitel 6 DAS WICHTIGSTE IN KÜRZE Zu Beginn des Jahres 2018 wurde in den Vereinigten Staaten mit dem Tax Cuts and Jobs Act (TCJA) eine umfangreiche Steuerreform umgesetzt, die zum einen die Steuersätze auf Arbeits- und Kapi- taleinkommen deutlich reduziert hat, zum anderen die Besteuerung multinationaler Unternehmen neu ordnet. Dies ist die größte Steuerreform seit dem Tax Reform Act 1986 und dürfte sich in viel- facher Hinsicht auf die Wirtschaft in den Vereinigten Staaten auswirken. Es ist eine zusätzliche Belebung des US-amerikanischen Wirtschaftswachstums zu erwarten, was wiederum das deut- sche Wirtschaftswachstum anregen dürfte. Mit Belgien, Frankreich und Italien haben Staaten mit ehemals höheren Steuersätzen als Deutsch- land ebenfalls die Steuersätze gesenkt und weitere Senkungen angekündigt. Bei den tariflichen Gewinnsteuersätzen rückt Deutschland damit allmählich wieder an die Spitze der OECD-Länder. Die Steuertarife sind jedoch nur ein Bestandteil eines Steuersystems. Die Bemessungsgrundlage, auf die der Steuersatz angewandt wird, ist gleichermaßen von Bedeutung. In diesem Kontext wird unter dem Begriff „Smart Tax Competition“ diskutiert, inwieweit steuerliche Anreize gezielt gesetzt werden können, um bestimmte, sehr mobile Aktivitäten anzuziehen. -
Raising Threshold for Bush Tax Cuts from $250000 to $1
820 First Street NE, Suite 510 Washington, DC 20002 Tel: 202-408-1080 Fax: 202-408-1056 [email protected] www.cbpp.org May 30, 2012 JOINT TAX COMMITTEE: RAISING THRESHOLD FOR BUSH TAX CUTS FROM $250,000 TO $1 MILLION WOULD LOSE $366 BILLION — NEARLY HALF THE REVENUE Revenue Loss Would Worsen Deficits and Increase Threats to Low-Income and Other Programs By Chuck Marr and Chye-Ching Huang House Minority Leader Nancy Pelosi’s proposal Raising Threshold for Extending to extend President Bush’s income tax cuts for Bush Tax Cuts Would Cost $366 Billion households making up to $1 million a year would Over First Decade lose nearly half of the revenue that President Obama’s proposal to extend the tax cuts only for households making up to $250,000 would raise, according to new estimates from Congress’ Joint Committee on Taxation (JCT). The higher threshold would raise 44 percent — or $366 billion — less in revenue over the coming decade than the lower threshold. Citizens for Tax Justice has released estimates showing a virtually identical percentage revenue loss. This means that policymakers ultimately would need to find $366 billion more in deficit savings to offset the cost. That would make key programs ranging from Medicare to Medicaid and other low-income programs to education, basic research, food safety, defense, and homeland security significantly more vulnerable to deep cuts. *Excludes additional savings from reduced interest on the The Obama proposal to extend income tax cuts debt. Savings exclude any reductions in estate tax cuts. only for those with incomes up to $250,000 would Source: Joint Committee on Taxation achieve $829 billion in much-needed deficit reduction over the next ten years, according to JCT (and $965 billion in total deficit reduction when debt-service savings are included). -
Creating Market Incentives for Greener Products Policy Manual for Eastern Partnership Countries
Creating Market Incentives for Greener Products Policy Manual for Eastern Partnership Countries Creating Incentives for Greener Products Policy Manual for Eastern Partnership Countries 2014 About the OECD The OECD is a unique forum where governments work together to address the economic, social and environmental challenges of globalisation. The OECD is also at the forefront of efforts to understand and to help governments respond to new developments and concerns, such as corporate governance, the information economy and the challenges of an ageing population. The Organisation provides a setting where governments can compare policy experiences, seek answers to common problems, identify good practice and work to co-ordinate domestic and international policies. The OECD member countries are: Australia, Austria, Belgium, Canada, Chile, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, the Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States. The European Union takes part in the work of the OECD. Since the 1990s, the OECD Task Force for the Implementation of the Environmental Action Programme (the EAP Task Force) has been supporting countries of Eastern Europe, Caucasus and Central Asia to reconcile their environment and economic goals. About the EaP GREEN programme The “Greening Economies in the European Union’s Eastern Neighbourhood” (EaP GREEN) programme aims to support the six Eastern Partnership countries to move towards green economy by decoupling economic growth from environmental degradation and resource depletion. The six EaP countries are: Armenia, Azerbaijan, Belarus, Georgia, Republic of Moldova and Ukraine. -
The Death of the Income Tax (Or, the Rise of America's Universal Wage
Indiana Law Journal Volume 95 Issue 4 Article 5 Fall 2000 The Death of the Income Tax (or, The Rise of America’s Universal Wage Tax) Edward J. McCaffery University of Southern California;California Institute of Tecnology, [email protected] Follow this and additional works at: https://www.repository.law.indiana.edu/ilj Part of the Estates and Trusts Commons, Law and Economics Commons, Taxation-Federal Commons, Taxation-Federal Estate and Gift Commons, Taxation-State and Local Commons, and the Tax Law Commons Recommended Citation McCaffery, Edward J. (2000) "The Death of the Income Tax (or, The Rise of America’s Universal Wage Tax)," Indiana Law Journal: Vol. 95 : Iss. 4 , Article 5. Available at: https://www.repository.law.indiana.edu/ilj/vol95/iss4/5 This Article is brought to you for free and open access by the Law School Journals at Digital Repository @ Maurer Law. It has been accepted for inclusion in Indiana Law Journal by an authorized editor of Digital Repository @ Maurer Law. For more information, please contact [email protected]. The Death of the Income Tax (or, The Rise of America’s Universal Wage Tax) EDWARD J. MCCAFFERY* I. LOOMINGS When Representative Alexandria Ocasio-Cortez, just weeks into her tenure as America’s youngest member of Congress, floated the idea of a sixty or seventy percent top marginal tax rate on incomes over ten million dollars, she was met with a predictable mixture of shock, scorn, and support.1 Yet there was nothing new in the idea. AOC, as Representative Ocasio-Cortez is popularly known, was making a suggestion with sound historical precedent: the top marginal income tax rate in America had exceeded ninety percent during World War II, and stayed at least as high as seventy percent until Ronald Reagan took office in 1981.2 And there is an even deeper sense in which AOC’s proposal was not as radical as it may have seemed at first. -
SHOULD WE TAX UNHEALTHY FOODS and DRINKS? Donald Marron, Maeve Gearing, and John Iselin December 2015
SHOULD WE TAX UNHEALTHY FOODS AND DRINKS? Donald Marron, Maeve Gearing, and John Iselin December 2015 Donald Marron is director of economic policy initiatives and Institute fellow at the Urban Institute, Maeve Gearing is a research associate at the Urban Institute, and John Iselin is a research assistant at the Urban-Brookings Tax Policy Center. The authors thank Laudan Aron, Kyle Caswell, Philip Cook, Stan Dorn, Lisa Dubay, William Gale, Genevieve Kenney, Adele Morris, Eric Toder, and Elaine Waxman for helpful comments and conversations; Joseph Rosenberg for running the Tax Policy Center model; Cindy Zheng for research assistance; Elizabeth Forney for editing; and Joanna Teitelbaum for formatting. This report was funded by the Laura and John Arnold Foundation. We thank our funders, who make it possible for Urban to advance its mission. The views expressed are those of the authors and should not be attributed to our funders, the Urban-Brookings Tax Policy Center, the Urban Institute, or its trustees. Funders do not determine our research findings or the insights and recommendations of our experts. For more information on our funding principles, go to urban.org/support. TAX POLICY CENTER | URBAN INSTITUTE & BROOKINGS INSTITUTION EXECUTIVE SUMMARY A healthy diet is essential to a long and vibrant life. But there is increasing evidence that our diets are not as healthy as we would like. Obesity, diabetes, hypertension, and other conditions linked to what we eat and drink are major challenges globally. By some estimates, obesity alone may be responsible for almost 3 million deaths each year and some $2 trillion in medical costs and lost productivity (Dobbs et al. -
The Urban-Brookings Tax Policy Center Microsimulation Model: Documentation and Methodology for Version 0304
The Urban-Brookings Tax Policy Center Microsimulation Model: Documentation and Methodology for Version 0304 Jeffrey Rohaly Adam Carasso Mohammed Adeel Saleem January 10, 2005 Jeffrey Rohaly is a research associate at the Urban Institute and director of tax modeling for the Tax Policy Center. Adam Carasso is a research associate at the Urban Institute. Mohammed Adeel Saleem is a research assistant at the Urban Institute. This documentation covers version 0304 of the model, which was developed in March 2004. The authors thank Len Burman and Kim Rueben for helpful comments and suggestions and John O’Hare for providing background on statistical matching. Views expressed are those of the authors and do not necessarily reflect the views of the Urban Institute, the Brookings Institution, their boards, or their sponsors. Documentation and Methodology: Tax Model Version 0304 A. Introduction.................................................................................................................... 3 Overview................................................................................................................................. 3 History..................................................................................................................................... 5 B. Source Data .................................................................................................................... 7 SOI Public Use File ............................................................................................................... -
The Bush Tax Cuts and the Economy
The Bush Tax Cuts and the Economy Thomas L. Hungerford Specialist in Public Finance December 10, 2010 Congressional Research Service 7-5700 www.crs.gov R41393 CRS Report for Congress Prepared for Members and Committees of Congress The Bush Tax Cuts and the Economy Summary A series of tax cuts were enacted early in the George W. Bush Administration by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA; P.L. 107-16) and the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA; P.L. 108-27). These tax cuts, which are collectively known as the Bush tax cuts, are scheduled to expire at the end of 2010. Beginning in 2011, many of the individual income tax parameters (such as tax rates) will revert back to 2000 levels. The major tax provisions in EGTRRA and JGTRRA that are part of the current debate over the Bush tax cuts are the reduced tax rates, the reduction of the marriage penalty (and increase in the marriage bonus), the repeal of the personal exemption phaseout and the limitation on itemized deductions, the reduced tax rates on long-term capital gains and qualified dividends, and expanded tax credits. This report examines the Bush tax cuts within the context of the current and long-term economic environment. The U.S. economy entered into a recession in December 2007. Between the fourth quarter of 2007 and the second quarter of 2009, the economy shrank with real gross domestic product (GDP) falling by 4.1%. The unemployment rate increased from 4.9% in December 2007 to 10.1% by October 2009, and is currently still over 9%. -
BEYOND PUBLIC CHOICE and PUBLIC INTEREST: a STUDY of the LEGISLATIVE PROCESS AS ILLUSTRATED by TAX LEGISLATION in the 1980S
University of Pennsylvania Law Review FOUNDED 1852 Formerly American Law Register VOL. 139 NOVEMBER 1990 No. 1 ARTICLES BEYOND PUBLIC CHOICE AND PUBLIC INTEREST: A STUDY OF THE LEGISLATIVE PROCESS AS ILLUSTRATED BY TAX LEGISLATION IN THE 1980s DANIEL SHAVIRO" TABLE OF CONTENTS I. INTRODUCTION ................................. 3 II. HISTORICAL OVERVIEW OF CYCLICAL TAX LEGISLATION ... 11 A. Legislation From the Beginning of the Income Tax Through the 1970s: The Evolution of Tax Instrumentalism and Tax Reform ..................................... 11 t Assistant Professor, University of Chicago Law School. The author was a Legislation Attorney with theJoint Committee of Taxation during the enactment of the 1986 tax bill discussed in this Article. He is grateful to Walter Blum, Richard Posner, Cass Sunstein, and the participants in a Harvard Law School seminar on Current Research in Taxation, held in Chatham, Massachusetts on August 23-26, 1990, for helpful comments on earlier drafts, to Joanne Fay and Michael Bonarti for research assistance, and to the WalterJ. Blum Faculty Research Fund and the Kirkland & Ellis Faculty Fund for financial support. 2 UNIVERSITY OF PENNSYLVANIA LAW REVIEW [Vol. 139: 1 B. The 1981 Act and Its Aftermath ................... 19 C. The 1986 Act ............................... 23 D. Aftermath of the 198.6 Act ......................... 29 E. Summary .................................. 30 III. THE PUBLIC INTEREST THEORY OF LEGISLATION ........ 31 A. The Various Strands of Public Interest Theory .......... 31 1. Public Interest Theory in Economics ............ 31 2. The Pluralist School in Political Science .......... 33 3. Ideological Views of the Public Interest .......... 35 B. Criticisms of PublicInterest Theory .................. 36 1. (Largely Theoretical) Criticisms by Economists ... 36 a. When Everyone "Wins," Everyone May Lose .. -
2019-Annual-Report.Pdf
2019 URBAN INSTITUTE ANNUAL REPORT A Message from the President Dear Friends, Inspired by our 50th anniversary, the Urban Institute kicked off our next 50 years in 2019 with a renewed commitment to advancing upward mobility, equity, and shared prosperity. We also collaborated with changemakers across the country to develop innovative ideas for how Urban could best fulfill our mission in light of trends likely to bring disruptive change in the decades to come. We did not expect such change to arrive in 2020 in the form of a pandemic that has exposed so many fissures in our society, including the disproportionate vulnerability of people of color to health and economic risks. Nor did we anticipate the powerful uprisings that have called needed attention to police brutality, antiblackness, and racism in our country. But as I consider the work Urban is undertaking to inform an inclusive recovery from the coronavirus pandemic and dismantle the systems and structures that drive racism, I am grateful for the many partners who, by engaging with our Next50 initiative in 2019, helped Urban accelerate the development of capacities and initiatives that are having an impact. Among the ways our work made a difference last year: ▪ Influencing efforts to boost Black homeownership. Our groundbreaking work on dramatic declines in Black homeownership helped make the issue an urgent concern in advocacy and policy circles. Urban delivered powerful new findings showing how a set of housing finance innovations can build wealth in communities of color. We also helped launch a collaborative effort with real estate professionals, lenders, and nonprofit leaders to amplify and solidify a framework for reducing the racial homeownership gap. -
Expanding Insurance Coverage for Children
XPANDING E INSURANCE COVERAGE FOR CHILDREN John Holahan XPANDING EINSURANCE COVERAGE FOR CHILDREN John Holahan Copyright © 1997. The Urban Institute. All rights reserved. Except for short quotes, no part of this publication may be reproduced or used in any form or by any means, electronic or mechanical including photo- copying, recording, or by information storage or retrieval system, with- out written permission from the Urban Institute. BOARD OF TRUSTEES URBAN INSTITUTE is a non- Richard B. Fisher profit policy research and educa- Chairman tional organization established in Joel L. Fleishman Vice Chairman Washington, D.C., in 1968. Its staff Katharine Graham investigates the social and economic Vice Chairman William Gorham problems confronting the nation and President public and private means to alleviate Jeffrey S. Berg Joan Toland Bok them. The Institute disseminates sig- Marcia L. Carsey nificant findings of its research Carol Thompson Cole Richard C. Green, Jr. through the publications program of Jack Kemp its Press. The goals of the Institute are Robert S. McNamara to sharpen thinking about societal Charles L. Mee, Jr. Robert C. Miller problems and efforts to solve them, Lucio Noto improve government decisions and Hugh B. Price Sol Price performance, and increase citizen Robert M. Solow awareness of important policy choices. Dick Thornburgh Judy Woodruff Through work that ranges from LIFE TRUSTEES broad conceptual studies to adminis- trative and technical assistance, Warren E. Buffett James E. Burke Institute researchers contribute to the Joseph A. Califano, Jr. stock of knowledge available to guide William T. Coleman, Jr. John M. Deutch decision making in the public interest. -
An Analysis of a Consumption Tax for California
An Analysis of a Consumption Tax for California 1 Fred E. Foldvary, Colleen E. Haight, and Annette Nellen The authors conducted this study at the request of the California Senate Office of Research (SOR). This report presents the authors’ opinions and findings, which are not necessarily endorsed by the SOR. 1 Dr. Fred E. Foldvary, Lecturer, Economics Department, San Jose State University, [email protected]; Dr. Colleen E. Haight, Associate Professor and Chair, Economics Department, San Jose State University, [email protected]; Dr. Annette Nellen, Professor, Lucas College of Business, San Jose State University, [email protected]. The authors wish to thank the Center for California Studies at California State University, Sacramento for their [email protected]; Dr. Colleen E. Haight, Associate Professor and Chair, Economics Department, San Jose State University, [email protected]; Dr. Annette Nellen, Professor, Lucas College of Business, San Jose State University, [email protected]. The authors wish to thank the Center for California Studies at California State University, Sacramento for their funding. Executive Summary This study attempts to answer the question: should California broaden its use of a consumption tax, and if so, how? In considering this question, we must also consider the ultimate purpose of a system of taxation: namely to raise sufficient revenues to support the spending goals of the state in the most efficient manner. Recent tax reform proposals in California have included a business net receipts tax (BNRT), as well as a more comprehensive sales tax. However, though the timing is right, given the increasingly global and digital nature of California’s economy, the recent 2008 recession tabled the discussion in favor of more urgent matters.