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Valuing Intellectual Capital, Multinationals and Taxhavens Springer Verlag 2013 Collected References, available on-line as <i.Stanford.edu/VIC/allVICcitations.pdf> 27-Oct-13 References for: Gio Wiederhold: Valuing Intellectual Capital, Multinationals and Taxhavens Springer Verlag 2013 VIC Citations This list includes all the references cited, as well as others that I have persused. For general information, I chose a recent publication for citation, trusting that it will be easier to locate and cite earlier work. As is common in tax matters, opinions abound. Refereed material is italicized. Entries cited and listed in the Reference section of Valuing Intelectual Capital have [bold identifiers]; entries considered, but not cited are marked ‡. Entries marked † were used for [W:06] . Transcription into the spreadsheet for VIC are marked [xls/worksheet]. Shaded text is to be omitted in publication, but helpful for search or as an aide de memoire. I am dding {chapter.section} references AAAAAAA [Aaron:13B] Henry J. Aaron: Tax Reform? Between a Rock and a Hard Place; Huffington Post, Brookings, 15 Jan. 2013. The 1986 reforms shifted $1T (adjusted) from individuals to Corportations over 10 years. Mobility of capital and the proliferation of multinatinal companies prevents such a solution now. Must raise personal income tax.{VIC Ch10.7.4} [Aaron:13G] Henry J. Aaron: You Get What You Pay For: Lessons From the IRS Scandal; Brookings, 31 May 2013. Only 1% of returns is audited. $450B is uncollected. Each dollar spent auditing yields $8. {VIC Ch8,7.3} [AbahoonieA:10]‡ Edward Abahoonie and Liah Alfonso: Deferred taxes on foreign earnings: A road map; Price Waterhouse Coopers (PwC), Dec.2010, updated 2012 www.pwc/us/tax. (with a nice picture of Luzern, Switzerland). {VIC Ch2.6} [Abba:97]† Wayne Abba: "Earned Value Management: Reconciling Government and Commercial Practices"; Program Manager, Vol.26, pp.58–69. {VIC Ch8.7.2} [AbramitzkyB:04] Ran Abramitzky and Fabio Braggion: Malthusian and Neo-Malthusian Theories; Oxford Encyclopedia of Economic History, Oxford University Press, 2004. At Stanford University.{VIC Ch9.4.5} [Acritas:10] Rankings of law firms employed for cross-border litigation and deals; BBW 27Sep.2010, p20. {VIC Ch8.7.4} [ACS360:09] Financial Accounting Standards Board: Property, Plant, and Equipment; Accounting Standards Codification 360-10-35-4, Depreciation, Version 3.0, 1 July 2009. Depreciation is a method of allocation, not of valuation. {VIC Ch3.4} [Actionaid:11] ActionAid: Addicted to tax havens, the secret life of the FTSE 100; ActionAid, UK, Oct.2011, http://www.actionaid.org.uk/doc_lib/addicted_to_tax_havens.pdfl. {VIC Ch8.5.3} [Adams:97] James D. Adams, 1997. "The Structure of Firm R&D and the Factor Intensity of Production“; NBER Working Papers 6099, National Bureau of Economic Research, Inc.; also Working Papers 97-15, Center for Economic Studies, U.S. Census Bureau. {VIC Ch5.7} [Adams:12] Scott Adams: Dilbert; Famous Quotes, Retrieved Jan. 2012. “There are many methods for predicting the future. For example, you can read horoscopes, tea leaves, tarot cards, or crystal balls. Collectively, these methods are known as `nutty methods.’ Or you can put well-researched facts into sophisticated computer models, more commonly referred to as `a complete waste of time’." {VIC Ch5.1} [ADLittle:85] ADLittle: Development of a Methodology for Estimating the Taxpayer Paperwork Burden; IRS, June 1988. Time cost for individual and business taxpayers $1813M, $3,614M = total 5,427M hours. [xls/irs] {VIC Ch8.2.2} [AF:04] The Appraisal Foundation: Uniform Standards of Professional Appraisal Practice; Standard 9, 2004 Edition. {VIC Ch.3.3} 1 [AgarwalG:99] Rajshree Agarwal and Michael Gort: First Mover Advantage and the Speed of Competitive Entry, 1887-1986; National Bureau of Economic Research (NBER), Sep.1999; SSRN library http://ssrn.com/abstract=167330. {VIC Ch7.4.1} [AghionH:94] Philippe Aghion and Peter Howitt: "Growth and Unemployment“; Review of Economic Studies, Wiley Blackwell, Vol.61 no.3), pp.477-494, July 1994; CEPR Discussion Papers 577. [AGN:08]‡ AGN International: The AGN European Region - 2008 Corporate Tax Survey, 2008 <http://www.agn-europe.org>. Annual surveys of ominal and effective tax rates. [xls/taxrates] {VIC Ch9..4.2} [Aiken:09] Alex Aiken: Measure of Software Similarity Software; MOSS software, 2009, <http://www.similix.com>. {VIC Ch5.1.i} [AJCA:04] U.S. Congress: American Jobs Creation Act; H.R.4520, Title VIII, Subtitle A, Section 422 (a) “965(a)(1)”, 2004. Sect 801 deals with inversions. {VIC Ch.2.5} {VIC Ch.2.7} [Albinus:12]‡ Phil Albinus: Fleeing Dodd-Frank, Hedge Funds Follow the Sun; Advanced Trading, 5 Jan 2012. Taxhavens protect bonuses. See [Kahn:12] .As of early November, the number of funds located in Malta had grown to more than 500 with 8 billion euros ($10.7 billion) under management from 165 funds with less than 5 billion euros under management in 2006, according to the Malta Financial Services Authority, or MFSA. [AlcockBG:09] Alistair Alcock, John Bird, and Steve Gale: Alcock, Bird and Gale on the Companies Act 2006; Jordans, 2009. s.172 CA 2006, "to promote the success of the company for the benefit of its members as a whole". It sets out six factors to which a director must have regards in fulfilling the duty to promote success. These are: 1. the likely consequences of any decision in the long term, 2.the interests of the company’s employees, 3.the need to foster the company’s business relationships with suppliers, customers and others, 4.the impact of the company’s operations on the community and the environment, 5.the desirability of the company maintaining a reputation for high standards of business conduct, and, 6.the need to act fairly as between members of a company. This represents a considerable departure from the traditional notion that directors' duties are owed only to the company. [Alderman:10] Liz Alderman: ”In Ireland, Low Corporate Taxes Go Untouched”; The New York Times, 25 Nov.2010. “The corporate tax is one of the pillars of Ireland’s economy, because it drives exports and jobs, and creates tax revenues for the government”; said Paul Duffy, a vice president at Pfizer in Ireland, one of the biggest multinational employers here. Raising the tax could scare away companies and “would damage a recovery and our ability to repay the massive debts we’ve taken on”; he said. /Critics, however, say that in addition to siphoning business from countries with higher corporate tax rates, some multinationals operating under Ireland’s tax rules use complicated schemes to move profits in and out of subsidiaries there. In some cases, that allows them to lower their effective tax rate, they say. /That has opened Ireland to criticism from countries like Germany, where Chancellor Angela Merkel must justify why taxpayers should help pay for another bailout package. The argument is that Ireland could be collecting more money from the companies it has lured. /Tax rates have become a contentious issue in Europe, where governments are competing as never before to lure badly needed foreign investments as the economic crisis weighs on growth. [AlmDM:04] James Alm, John Deskins, And Michael McKee: Tax Evasion and Entrepreneurship: The Effect of Income reporting Policies on Evasion; 97th Annual Conference of the National Tax Association, Minneapolis, MN, Nov.2004. An audit rate of 10% vs 30% doubles non-compliance. [Allan:11] Robert B. Allen ([email protected]): Information: A Fundamental Construct; <http://boballen.info/ISS/. The text is still under development , 2011. [Almeida:04] Aloisio Almeida: Tax Havens: An Analysis of the OECD Work with Policy Recommendations; Ford School of Public Policy, Apr.2004. 5 uncooperative jurisdiections: Andorra, Liberia, Liechtenstein, Monaco, Marshall Islands. Three were removed in 2000: Barbados, Maldives, Tonga, 33 will fix ttransparency. [alSayigh:78] Yusif al Sayigh: World Economic Outlook Conf.; Economic Advisor. Arab Fund for Social and Economic Development, 9-10 Nov 1978. Quotes Arab proverb: "Listen and you will be very happy, but look and you will be terribly sad". [VIC Ch.NNNNN] [Alter:11] Jonathan Alter: Coming Lobbyist Brawl May (Really) Fix Our Taxes; Bloomberg Businessweek, 5 Aug 2011. the author of “The Defining Moment: FDR’s Hundred Days and the Triumph of Hope” . On the supercommittee’s chances. [AltmanEa:12] Roger Altman, William Daley, John Podesta, Robert Rubin, Leslie Samuels,Lawrence Summers, Neera Tanden, and Antonio Weiss with Michael Ettlinger, Seth Hanlon, Michael Linden: Reforming Our Tax System, Reducing Our Deficit; American Progress, Dec. 2012 [Altshuler:10] Rosanne Altshuler: “Capital income taxation and progressivity in a global econmy”; Virginia Tax Review, 22 Sep.2010. see [AltshulerHT:10] [AltshulerACK:08] Rosanne Altshuler, Alan J. Auerbach, Michael Cooper, and Mathew Knittel: Understanding U.S. Corporate Tax Losses; NBER Tax Policy and the Economy Conference, Washington, DC, 6.Oct.2008. Tax expenditures , Many Graphs. Uses form 1120 data. Cooper and Knittel are with the Treasury.”...taxpayers can engage in .excessive. or in some other way unintended use of legal tax provisions to reduce tax liabilities.” [AltshulerG:01] Rosanne Altshuler and Harry Grubert: “Where Will They Go if We Go Territorial? Dividend Exemption and the Foreign Location Decisions of U.S. Multinational Corporations”; National Tax Journal, Vol.54 No.4, Dec.2001, pp.787-809. [AltshulerM:96]‡ Rosanne Altshuler and Jack M. Mintz: “United States Interest-Allocation Rules, Effects and Policy”; in [Slemrod:96] . [AltshulerHT:10] Rosanne Altshuler, Benjamin Harris, and Eric Toder: “Capital Income Taxation and Progressivity in a Global Economy”; Virginia Tax Review, Vol.30, Fall 2010, pp.355-388. Tax gains at 28% and dividends fully yields $87B to reduce corporate tax from 35% to 26%. [Amadi:02] Confidence W. Amadi: Double Taxation of Dividends: A Clarification <http://www.westga.edu/~bquest/2002/double.htm>. “The greatest advantage of the corporate form of business organization is the limited liability protection accorded its owners.
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