Global Organizations and Taxes an Analysis of the Dividend, Interest
Total Page:16
File Type:pdf, Size:1020Kb
Load more
Recommended publications
-
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 .. -
An Analysis of the Graded Property Tax Robert M
TaxingTaxing Simply Simply District of Columbia Tax Revision Commission TaxingTaxing FairlyFairly Full Report District of Columbia Tax Revision Commission 1755 Massachusetts Avenue, NW, Suite 550 Washington, DC 20036 Tel: (202) 518-7275 Fax: (202) 466-7967 www.dctrc.org The Authors Robert M. Schwab Professor, Department of Economics University of Maryland College Park, Md. Amy Rehder Harris Graduate Assistant, Department of Economics University of Maryland College Park, Md. Authors’ Acknowledgments We thank Kim Coleman for providing us with the assessment data discussed in the section “The Incidence of a Graded Property Tax in the District of Columbia.” We also thank Joan Youngman and Rick Rybeck for their help with this project. CHAPTER G An Analysis of the Graded Property Tax Robert M. Schwab and Amy Rehder Harris Introduction In most jurisdictions, land and improvements are taxed at the same rate. The District of Columbia is no exception to this general rule. Consider two homes in the District, each valued at $100,000. Home A is a modest home on a large lot; suppose the land and structures are each worth $50,000. Home B is a more sub- stantial home on a smaller lot; in this case, suppose the land is valued at $20,000 and the improvements at $80,000. Under current District law, both homes would be taxed at a rate of 0.96 percent on the total value and thus, as Figure 1 shows, the owners of both homes would face property taxes of $960.1 But property can be taxed in many ways. Under a graded, or split-rate, tax, land is taxed more heavily than structures. -
Canada Taxation of Foreign Passive Income (FAPI)
INTERNATIONAL TAX POLICY FORUM / GEORGETOWN UNIVERSITY LAW CENTER Reform of International Tax: Canada, Japan, United Kingdom, and United States January 21, 2011 Gewirz Student Center, 12th floor 120 F Street, N.W., Washington, D.C. 20036 International Tax Policy Forum International Tax Policy Forum and Georgetown University Law Center Conference on: REFORM OF INTERNATIONAL TAX: CANADA, JAPAN, UNITED KINGDOM, AND UNITED STATES Table of Contents 1) Agenda ................................................................................................................................................... 1 2) Sponsoring Organizations a) About ITPF ....................................................................................................................................... 2 b) About Georgetown University Law Center ....................................................................................... 3 3) Taxation of International Income in Canada, Japan, UK, and US a) International Tax Rules in Canada, Japan, the UK and US (J. Mintz Presentation) ....................... 4 b) Canada i) S. Richardson, Presentation on Canadian international tax reform (Jan. 2011) ....................... 9 ii) N. Pantaleo, Presentation on Canada's taxation of foreign business income (Jan. 2011) ..... 12 iii) Advisory Panel on Canada’s System of International Taxation, Enhancing Canada’s International Tax Advantage, (Dec. 2008) [Executive Summary] ........................................... 16 c) UK i) M. Williams, Presentation on UK international tax -
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. -
By Laura Saunders, Richard Rubin and the Staff of the Wall Street Journal ACKNOWLEDGMENTS
The New World of Taxes: 2019 By Laura Saunders, Richard Rubin and the staff of The Wall Street Journal ACKNOWLEDGMENTS The lead authors of this book were Laura Saunders, Richard Rubin, Theo Francis and Nick Timiraos, along with co-authors Stephanie Armour, Drew FitzGerald, Sarah Krouse, Laura Kusisto, Peter Loftus, Sarah Nassauer, Michael Rapoport, Jonathan Rockoff and Anne Tergesen. The news editor was David Marcelis and lead editor was Amber Burton. TABLE OF CONTENTS INTRODUCTION Alimony ........................................................31 Other Deductions .................................. 32 THE BIG PICTURE Tax Rates and Brackets ........................4 RETIREMENT AND EDUCATION Standard Deduction Retirement Savings .............................34 and Personal Exemption ......................6 Retiree Tax Issues ................................. 35 Child and Dependent 529 Education- Tax Credit .......................................................8 Savings Accounts ...................................37 Withholding and Estimated Other Education Tax Payments ...........................................10 Benefits ....................................................... 39 Taxes on Investment Income ...........11 FOR BUSINESS OWNERS Alternative Minimum Tax ................. 13 Pass-Through Income ..........................41 Individual Mandate ...............................15 Interest Payments ................................ 43 Home-Sellers’ Exemption .................16 Depreciation .............................................44 -
Corporate Tax Changes in the 1986 Tax Reform Act Richard E
College of William & Mary Law School William & Mary Law School Scholarship Repository William & Mary Annual Tax Conference Conferences, Events, and Lectures 1986 Corporate Tax Changes in the 1986 Tax Reform Act Richard E. May Repository Citation May, Richard E., "Corporate Tax Changes in the 1986 Tax Reform Act" (1986). William & Mary Annual Tax Conference. 558. https://scholarship.law.wm.edu/tax/558 Copyright c 1986 by the authors. This article is brought to you by the William & Mary Law School Scholarship Repository. https://scholarship.law.wm.edu/tax THIRTY-SECOND WILLIAM AND MARY TAX CONFERENCE CORPORATE TAX CHANGES IN THE 1986 TAX REFORM ACT by Richard E.. May Hunton & Williams December 5-6, 1986 Williamsburg The speaker wishes to acknowledge that portions of this outline were graciously made available by Messrs. Mark J. Silverman, William C. Bowers, and Robert H. Wellen, all colleagues in the Section of Taxation of the American Bar Association. CORPORATE TAX CHANGES IN 1986 TAX REFORM ACT I. Selected changes affecting taxation of corporations.* A. Corporate rate changes. The 1986 Act makes changes to the corporate rates for both ordinary income and capital gains. Each is described below. 1. Rates for ordinary income. (1986 Act, § 601). The 1986 Act sets the maximum corporate rate on ordinary income at 34 percent for taxable income in excess of 75,000. Lower rates apply to taxable income below that amount as follows: Taxable Income Tax Rate $50,000 or less 15% $50,001 - $75,000 25% $75,001 or more 34% There is a phase-out of the benefit of the two lower rates of tax. -
Federal Revenue Options Testimony Submitted to United States House Of
Federal Revenue Options Testimony submitted to United States House of Representatives Committee on the Budget October 6, 2004 William G. Gale1 Brookings Institution Tax Policy Center Chairman Nussle, Ranking Member Spratt, and Members of the Committee: Thank you for inviting me to testify today on federal revenue options. Almost everyone concurs that the tax system could be improved. But agreement on the nature and severity of the problems and how to resolve them remains elusive. The basic goals of tax reform seem clear. First, taxes should be simple. Second, taxes should be fair. Third, taxes should be conducive to economic prosperity and market efficiency. Fourth, they should raise sufficient revenue to cover the “appropriate” level of government. Fifth, to the greatest extent possible, tax rules should respect people's freedom and privacy.2 Despite the "motherhood and apple pie" quality of these goals, tax policy remains controversial. One problem is that controversy arises over how to achieve each goal. Supporters of increased growth disagree over whether across-the-board income tax cuts, targeted tax cuts for saving and investment, or paying down public debt will do most for the economy. Another obstacle to consensus is that the goals are imprecise: views of what constitutes a fair tax, for example, vary widely. The most important source of controversy, however, is differing value judgments concerning the relative importance of the goals coupled with the fact that the goals sometimes conflict with one another. Research and data may answer technical questions, but they cannot resolve disagreements based on divergent values and preferences. One strategy for reform is to improve the performance of the existing tax system. -
Administration's Fiscal Year 2014 Revenue Proposals
General Explanations of the Administration’s Fiscal Year 2014 Revenue Proposals Department of the Treasury April 2013 General Explanations of the Administration’s Fiscal Year 2014 Revenue Proposals Department of the Treasury April 2013 This document is available online at: http://www.treasury.gov/resource-center/tax-policy/Documents/General-Explanations-FY2014.pdf TABLE OF CONTENTS ADJUSTMENTS TO THE BALANCED BUDGET AND EMERGENCY DEFICIT CONTROL ACT (BBEDCA) BASELINE .......................................... 1 Permanently Extend Increased Refundability of the Child Tax Credit ............................... 2 Permanently Extend Earned Income Tax Credit (EITC) for Larger Families and Married Couples ................................................................................................................... 4 Permanently Extend the American Opportunity Tax Credit (AOTC) ................................. 6 RESERVE FOR REVENUE-NEUTRAL BUSINESS TAX REFORM ............. 9 INCENTIVES FOR MANUFACTURING, RESEARCH, CLEAN ENERGY, AND INSOURCING AND CREATING JOBS ............................................................................. 10 Provide Tax Incentives for Locating Jobs and Business Activity in the United States and Remove Tax Deductions for Shipping Jobs Overseas ........................................... 10 Provide New Manufacturing Communities Tax Credit .................................................... 12 Enhance and Make Permanent the Research and Experimentation (R&E) Tax Credit ... 13 Extend Certain Employment Tax -
Report No. 82-156 Gov Major Acts of Congress And
REPORT NO. 82-156 GOV MAJOR ACTS OF CONGRESS AND TREATIES APPROVED BY THE SENATE 1789-1980 Christopher Dell Stephen W. Stathis Analysts in American National Governent Government Division September 1982 CONmGHnItNA^l JK 1000 B RE filmH C SE HVICA^^ ABSTRACT During the nearly two centuries since the framing of the Constitution, more than 41,000 public bills have been approved by Congress, submitted to the President for his approval and become law. The seven hundred or so acts summarized in this compilation represent the major acts approved by Congress in its efforts to determine national policies to be carried out by the executive branch, to authorize appropriations to carry out these policies, and to fulfill its responsibility of assuring that such actions are being carried out in accordance with congressional intent. Also included are those treaties considered to be of similar importance. An extensive index allows each entry in this work to be located with relative ease. The authors wish to credit Daphine Lee, Larry Nunley, and Lenora Pruitt for the secretarial production of this report. CONTENTS ABSTRACT.................................................................. 111 CONGRESSES: 1st (March 4, 1789-March 3, 1791)..................................... 3 2nd (October 24, 1791-March 2, 1793)................................... 7 3rd (December 2, 1793-March 3, 1795).................................. 8 4th (December 7, 1795-March 3, 1797).................................. 9 5th (May 15, 1797-March 3, 1799)....................................... 11 6th (December 2, 1799-March 3, 1801)................................... 13 7th (December 7, 1801-Marh 3, 1803)................................... 14 8th (October 17, 1803-March 3, 1805)....... ........................... 15 9th (December 2, 1805-March 3, 1807)................................... 16 10th (October 26, 1807-March 3, 1809).................................. -
United States Tax Treaty Policy: an Overview H
University of Miami Law School University of Miami School of Law Institutional Repository Articles Faculty and Deans 1981 United States Tax Treaty Policy: An Overview H. David Rosenbloom Stanley Langbein University of Miami School of Law, [email protected] Follow this and additional works at: https://repository.law.miami.edu/fac_articles Part of the Taxation-Transnational Commons, and the Tax Law Commons Recommended Citation H. David Rosenbloom and Stanley Langbein, United States Tax Treaty Policy: An Overview, 19 Colum. J. Transnat'l L. 359 (1981). This Article is brought to you for free and open access by the Faculty and Deans at University of Miami School of Law Institutional Repository. It has been accepted for inclusion in Articles by an authorized administrator of University of Miami School of Law Institutional Repository. For more information, please contact [email protected]. United States Tax Treaty Policy: An Overview* H. DAVID ROSENBLOOMt AND STANLEY I. LANGBEINt EDITOR'S NoTE: The following is a slightly revised transcriptof an April 29, 1980 statement by the then-International Tax Counsel of the Department of the Treasury before the Subcommittee on Oversight of the House Ways and Means Committee. Except for some minor stylistic changes and non-substantive abridgements, it conforms to the Department of the Treasury News release of April 29, 1980, which originally reported the testimony. In the view of the Journal, the discussion of tax treaty policy and provi- sions appearing in the statement - which has not received wide dissemination - merits its inclusion in this InternationalTax Is- sue. Permission to reprint the statements was secured from the authors. -
An Economic Analysis
The “Better Way” House Tax Plan: An Economic Analysis Jane G. Gravelle Senior Specialist in Economic Policy Updated August 3, 2017 Congressional Research Service 7-.... www.crs.gov R44823 The “Better Way” House Tax Plan: An Economic Analysis Summary On June 24, 2016, House Speaker Paul Ryan released the Better Way Tax Reform Task Force Blueprint, which provides a revision of federal income taxes. For the individual income tax, the plan would broaden the base, lower the rates (with a top rate of 33%), and alter some of the elements related to family size and structure by eliminating personal exemptions, allowing a larger standard deduction, and adding a dependent credit. For business income, the current income tax would be replaced by a cash-flow tax rebated on exports and imposed on imports, with a top rate of 20% for corporations and 25% for individuals. The cash-flow tax would be border-adjusted (imports taxed and exports excluded), making domestic consumption the tax base, although a recent announcement from congressional leaders has indicated that a border adjustment would be dropped in any future tax plan. The system would also move to a territorial tax in which foreign source income (except for easily abused income) would not be taxed. In addition, the proposal would repeal estate and gift taxes. Although the Affordable Care Act (ACA) taxes are not repealed in the Better Way tax reform proposal, ACA taxes are repealed in the Healthcare Task Force proposals. One objective of tax reform is to increase output and efficiency. However, the plan’s estimated output effects appear to be limited in size and possibly negative. -
JAMES A. BAKER, III the Case for Pragmatic Idealism Is Based on an Optimis- Tic View of Man, Tempered by Our Knowledge of Human Imperfection
Extract from Raising the Bar: The Crucial Role of the Lawyer in Society, by Talmage Boston. © State Bar of Texas 2012. Available to order at texasbarbooks.net. TWO MOST IMPORTANT LAWYERS OF THE LAST FIFTY YEARS 67 concluded his Watergate memoirs, The Right and the Power, with these words that summarize his ultimate triumph in “raising the bar”: From Watergate we learned what generations before us have known: our Constitution works. And during the Watergate years it was interpreted again so as to reaffirm that no one—absolutely no one—is above the law.29 JAMES A. BAKER, III The case for pragmatic idealism is based on an optimis- tic view of man, tempered by our knowledge of human imperfection. It promises no easy answers or quick fixes. But I am convinced that it offers our surest guide and best hope for navigating our great country safely through this precarious period of opportunity and risk in world affairs.30 In their historic careers, Leon Jaworski and James A. Baker, III, ended up in the same place—the highest level of achievement in their respective fields as lawyers—though they didn’t start from the same place. Leonidas Jaworski entered the world in 1905 as the son of Joseph Jaworski, a German-speaking Polish immigrant, who went through Ellis Island two years before Leon’s birth and made a modest living as an evangelical pastor leading small churches in Central Texas towns. James A. Baker, III, entered the world in 1930 as the son, grand- son, and great-grandson of distinguished lawyers all named James A.