1 How Do War Financing Strategies Lead to Inequality?
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A Requiem for the Rollover Rule: Capital Gains, Farmland Loss, and the Law of Unintended Consequences
University of Arkansas ∙ System Division of Agriculture [email protected] ∙ (479) 575-7646 An Agricultural Law Research Article A Requiem for the Rollover Rule: Capital Gains, Farmland Loss, and the Law of Unintended Consequences by Christine A. Klein Originally published in WASHINGTON & LEE LAW REVIEW 55 WASH. & LEE L. REV. 403 (1998) www.NationalAgLawCenter.org A Requiem for the Rollover Rule: Capital Gains, Farmland Loss, and the Law of Unintended Consequences Christine A. Klein' Table ofContents I. Introduction........................................ 404 II. The "American Dream" Narrative: Tax Preferences for Home Owners .................................... .. 407 A. The Home Sale Preference of Former § 1034 . .. 410 B. The Ambivalent Taxation of Capital Gains 412 III. The Restrictive Subtext: The Rollover Rule 414 A. The Rollover Mechanism , 416 B. Converting the Involuntary Conversion Provision 420 C. A Case of Mistaken Identity: Is a Home Like a Ship? . .. 422 IV. The Revenue Act of 1951 424 A. War and Taxes ................................ .. 425 B. From Hot War to Cold War. ..................... .. 427 C. A Bipartisan Oasis: The Home Sale Preference . .. 432 V. The Unintended Consequences ofthe Rollover Rule: Three Hypotheses 433 A. Over-Investment in Housing 434 B. Inflation of Housing Prices 437 C. Conversion ofFarmland into Suburban Housing 438 VI. A Tale of Two Counties: A Case Study 439 A. Santa Clara County, California: 1990-96 441 B. Boulder County, Colorado: 1990-96................. 443 I. Over-Investment in Housing 446 * Associate Professor of Law, Detroit College of Law at Michigan State University. LL.M., Columbia University; J.D., University of Colorado; B.A., Middlebury College. I am grateful to Michael C. -
American War and Military Operations Casualties: Lists and Statistics
American War and Military Operations Casualties: Lists and Statistics Nese F. DeBruyne Senior Research Librarian Updated September 14, 2018 Congressional Research Service 7-5700 www.crs.gov RL32492 American War and Military Operations Casualties: Lists and Statistics Summary This report provides U.S. war casualty statistics. It includes data tables containing the number of casualties among American military personnel who served in principal wars and combat operations from 1775 to the present. It also includes data on those wounded in action and information such as race and ethnicity, gender, branch of service, and cause of death. The tables are compiled from various Department of Defense (DOD) sources. Wars covered include the Revolutionary War, the War of 1812, the Mexican War, the Civil War, the Spanish-American War, World War I, World War II, the Korean War, the Vietnam Conflict, and the Persian Gulf War. Military operations covered include the Iranian Hostage Rescue Mission; Lebanon Peacekeeping; Urgent Fury in Grenada; Just Cause in Panama; Desert Shield and Desert Storm; Restore Hope in Somalia; Uphold Democracy in Haiti; Operation Enduring Freedom (OEF); Operation Iraqi Freedom (OIF); Operation New Dawn (OND); Operation Inherent Resolve (OIR); and Operation Freedom’s Sentinel (OFS). Starting with the Korean War and the more recent conflicts, this report includes additional detailed information on types of casualties and, when available, demographics. It also cites a number of resources for further information, including sources of historical statistics on active duty military deaths, published lists of military personnel killed in combat actions, data on demographic indicators among U.S. military personnel, related websites, and relevant Congressional Research Service (CRS) reports. -
Economics During the Lincoln Administration
4-15 Economics 1 of 4 A Living Resource Guide to Lincoln's Life and Legacy ECONOMICS DURING THE LINCOLN ADMINISTRATION War Debt . Increased by about $2 million per day by 1862 . Secretary of the Treasury Chase originally sought to finance the war exclusively by borrowing money. The high costs forced him to include taxes in that plan as well. Loans covered about 65% of the war debt. With the help of Jay Cooke, a Philadelphia banker, Chase developed a war bond system that raised $3 billion and saw a quarter of middle class Northerners buying war bonds, setting the precedent that would be followed especially in World War II to finance the war. Morrill Tariff Act (1861) . Proposed by Senator Justin S. Morrill of Vermont to block imported goods . Supported by manufacturers, labor, and some commercial farmers . Brought in about $75 million per year (without the Confederate states, this was little more than had been brought in the 1850s) Revenue Act of 1861 . Restored certain excise tax . Levied a 3% tax on personal incomes higher than $800 per year . Income tax first collected in 1862 . First income tax in U. S. history The Legal Tender Act (1862) . Issued $150 million in treasury notes that came to be called greenbacks . Required that these greenbacks be accepted as legal tender for all debts, public and private (except for interest payments on federal bonds and customs duties) . Investors could buy bonds with greenbacks but acquire gold as interest United States Note (Greenback). EarthLink.net. 18 July 2008 <http://home.earthlink.net/~icepick119/page11.html> Revenue Act of 1862 Office of Curriculum & Instruction/Indiana Department of Education 09/08 This document may be duplicated and distributed as needed. -
An American Perspective on the War of 1812 by Donald Hickey
An American Perspective on the War of 1812 By Donald Hickey The War of 1812 is probably our most obscure conflict. Although Navy’s practice of removing seamen from American merchant regulars of Great Britain. Similarly, the naval victories on the War of Independence”–they could point to few concrete gains– a great deal has been written about the war, the average American vessels. In contemporary parlance, the war was fought for northern lakes and the high seas and the success of privateers certainly none in the peace treaty–to sustain this claim. is only vaguely aware of why we fought or who the enemy was. “Free Trade and Sailors’ Rights.” These issues seem arcane around the globe demonstrated that, given the right odds, the Even those who know something about the contest are likely to today. Moreover, the only way that the United States to strike nation’s armed ships matched up well against even the vaunted It is this lack of success that may best explain why the war is so remember only a few dramatic moments, such as the writing of at Great Britain was by attacking Canada, and that made it and seemingly invincible Mistress of the Seas. little remembered. Americans have characteristically judged “The Star-Spangled Banner,” the burning of the nation’s capital, look like a war of territorial aggression. Even today Canadians their wars on the basis of their success. The best-known wars– or the Battle of New Orleans. are likely to see the war in this light, and who can blame them? The war also produced its share of heroes–people whose reputations the Revolution, the Civil War, and World War II–were all A war fought to secure maritime rights by invading Canada were enhanced by military or government service. -
Mayo Clinic, a Minnesota Corporation
United States Court of Appeals For the Eighth Circuit ___________________________ No. 19-3189 ___________________________ Mayo Clinic, a Minnesota Corporation lllllllllllllllllllllPlaintiff - Appellee v. United States of America lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the District of Minnesota ____________ Submitted: October 20, 2020 Filed: May 13, 2021 ____________ Before SMITH, Chief Judge, LOKEN and GRUENDER, Circuit Judges. ____________ LOKEN, Circuit Judge. Mayo Clinic (“Mayo”), a Minnesota nonprofit corporation, oversees healthcare system subsidiaries and operates the Mayo Clinic College of Medicine and Science (“Mayo College”). Mayo is a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code (IRC), 26 U.S.C. § 501(c)(3).1 After an audit in 2009, the Internal Revenue Service concluded that Mayo owed unrelated business income tax (“UBIT”) on certain investment income it received from the investment pool it manages for its subsidiaries. The IRS issued a Notice of Proposed Adjustment and reaffirmed its position in a 2013 Technical Advice Memorandum. At issue is $11,501,621 in UBIT for tax years 2003, 2005-2007, and 2010-2012. Mayo2 paid the tax and brought this refund action. The issue, briefly stated, is whether Mayo is a “qualified organization” exempted from paying UBIT on “unrelated debt-financed income” under IRC § 514(c)(9)(C)(i). Qualified organizations include “an organization described in section 170(b)(1)(A)(ii) . .” Section 170(b)(1)(A)(ii) describes “an educational organization which normally maintains a regular faculty and curriculum and normally has a regularly enrolled body of pupils or students in attendance at the place where its educational activities are regularly carried on.” The IRS denied Mayo the exemption because it is not an “educational organization” as defined in 26 C.F.R. -
RESTORING the LOST ANTI-INJUNCTION ACT Kristin E
COPYRIGHT © 2017 VIRGINIA LAW REVIEW ASSOCIATION RESTORING THE LOST ANTI-INJUNCTION ACT Kristin E. Hickman* & Gerald Kerska† Should Treasury regulations and IRS guidance documents be eligible for pre-enforcement judicial review? The D.C. Circuit’s 2015 decision in Florida Bankers Ass’n v. U.S. Department of the Treasury puts its interpretation of the Anti-Injunction Act at odds with both general administrative law norms in favor of pre-enforcement review of final agency action and also the Supreme Court’s interpretation of the nearly identical Tax Injunction Act. A 2017 federal district court decision in Chamber of Commerce v. IRS, appealable to the Fifth Circuit, interprets the Anti-Injunction Act differently and could lead to a circuit split regarding pre-enforcement judicial review of Treasury regulations and IRS guidance documents. Other cases interpreting the Anti-Injunction Act more generally are fragmented and inconsistent. In an effort to gain greater understanding of the Anti-Injunction Act and its role in tax administration, this Article looks back to the Anti- Injunction Act’s origin in 1867 as part of Civil War–era revenue legislation and the evolution of both tax administrative practices and Anti-Injunction Act jurisprudence since that time. INTRODUCTION .................................................................................... 1684 I. A JURISPRUDENTIAL MESS, AND WHY IT MATTERS ...................... 1688 A. Exploring the Doctrinal Tensions.......................................... 1690 1. Confused Anti-Injunction Act Jurisprudence .................. 1691 2. The Administrative Procedure Act’s Presumption of Reviewability ................................................................... 1704 3. The Tax Injunction Act .................................................... 1707 B. Why the Conflict Matters ....................................................... 1712 * Distinguished McKnight University Professor and Harlan Albert Rogers Professor in Law, University of Minnesota Law School. -
The Joint Committee on Taxation and Codification of the Tax Laws
The Joint Committee on Taxation and Codification of the Tax Laws George K. Yin Edwin S. Cohen Distinguished Professor of Law and Taxation University of Virginia Former Chief of Staff, Joint Committee on Taxation February 2016 Draft prepared for the United States Capitol Historical Society’s program on The History and Role of the Joint Committee: the Joint Committee and Tax History Comments welcome. THE UNITED STATES CAPITOL HISTORICAL SOCIETY THE JCT@90 WASHINGTON, DC FEBRUARY 25, 2016 The Joint Committee on Taxation and Codification of the Tax Laws George K. Yin* February 11, 2016 preliminary draft [Note to conference attendees and other readers: This paper describes the work of the staff of the Joint Committee on Internal Revenue Taxation (JCT)1 that led to codification of the tax laws in 1939. I hope eventually to incorporate this material into a larger project involving the “early years” of the JCT, roughly the period spanning the committee’s creation in 1926 and the retirement of Colin Stam in 1964. Stam served on the staff for virtually this entire period; he was first hired (on a temporary basis) in 1927 as assistant counsel, became staff counsel in 1929, and then served as Chief of Staff from 1938 until 1964. He is by far the longest‐serving Chief of Staff the committee has ever had. The conclusions in this draft are still preliminary as I have not yet completed my research. I welcome any comments or questions.] Possibly the most significant accomplishment of the JCT and its staff during the committee’s “early years” was the enactment of the Internal Revenue Code of 1939. -
Measuring Tax Burden: a Historical Perspective
This PDF is a selection from an out-of-print volume from the National Bureau of Economic Research Volume Title: Fifty Years of Economic Measurement: The Jubilee of the Conference on Research in Income and Wealth Volume Author/Editor: Ernst R. Berndt and Jack E. Triplett, editors Volume Publisher: University of Chicago Press Volume ISBN: 0-226-04384-3 Volume URL: http://www.nber.org/books/bern91-1 Conference Date: May 12-14, 1988 Publication Date: January 1991 Chapter Title: Measuring Tax Burden: A Historical Perspective Chapter Author: B. K. Atrostic, James R. Nunns Chapter URL: http://www.nber.org/chapters/c5981 Chapter pages in book: (p. 343 - 420) 11 Measuring Tax Burden: A Historical Perspective B. K. Atrostic and James R. Nunns 11.1 Introduction 11.1.1 Overview Measures of tax burden are indicators of how well tax policy meets one of its primary goals, equitably raising the revenues needed to run government. Equity has two aspects. The first, vertical equity, concerns the way taxes are distributed among taxpayers with different abilities to pay. The second, hori- zontal equity, concerns the way taxes are distributed among taxpayers with the same ability to pay. Tax burden measures thus answer broad economic and social questions about the effect of tax policy on the distribution of income and wealth. The history of these measures incorporates the histories of economic and world affairs, major tax and economic policy legislation, intellectual and so- cial movements, and data and technological innovation in the fifty years since the first meeting of the Conference on Research in Income and Wealth. -
War of 1812 Brief History by Susan L
War of 1812 Brief History By Susan L. Conklin, Genesee County Historian In 1811 while Canada supplied reinforcements to the Niagara River area, the United States made no comparable effort to strengthen its undermanned Fort Niagara. However, in 1809 Joseph Ellicott, Resident-Agent for the Holland Land Company, had built a temporary arsenal in Batavia and Daniel D. Tompkins, the Governor of New York State, agreed to supply weapons to improve the defense west of the Genesee River. In 1812 Western New York was composed of five counties; in the south, Allegany, Chautauqua, Cattaraugus and in the north Genesee (which included all of Orleans, Wyoming and the western sections of Livingston and Monroe) and Niagara (which included Erie). On June 18, 1812 the United States Congress declared war on Great Britain. The causes of the war included trade tensions, British support for Indian raids and U.S. territory expansion. The news of this declaration caused great concern and dread among the settlers of Western New York. All able-bodied men were summoned to fight and join the militia, leaving only a few behind to manage the crops. Seneca warriors from the Tonawanda Reservation also volunteered and provided support to the local militia. For a year and a half there had been fighting along the Niagara River and in the later part of 1813 both sides of the river were controlled by the American troops. On December 10, 1813 General George McClure, who had been left in charge of the garrison at Fort George, on the Canadian side, attacked the Canadian Village of Newark (renamed Niagara) which was located one mile north of the fort. -
The Progressive Movement and the Reforming of the United States of America, from 1890 to 1921
2014 Democratic and Popular Republic of Algeria. Ministry of Higher Education and Scientific Research. University of Oran. Faculty of Letters, Languages, and Arts. Department of English. Research Paper Submitted for a Doctorate Thesis in American Civilisation Entitled: The Progressive Movement and the Reforming of the United States of America, from 1890 to 1921. Presented by: Benketaf, Abdel Hafid. Jury Members Designation University Pr. Bouhadiba, Zoulikha President Oran Pr. Borsali, Fewzi Supervisor Adrar Pr. Bedjaoui, Fouzia Examiner 1 Sidi-Belabes Dr. Moulfi, Leila Examiner 2 Oran Dr. Belmeki, Belkacem Examiner 3 Oran Dr. Afkir, Mohamed Examiner 4 Laghouat Academic Year: 2013-2014. 1 Acknowledgements Acknowledgments are gratefully made for the assistance of numerous friends and acquaintances. The largest debt is to Professor Borsali, Fewzi because his patience, sound advice, and pertinent remarks were of capital importance in the accomplishment of this thesis. I would not close this note of appreciation without alluding to the great aid provided by my wife Fatima Zohra Melki. 2 Dedication To my family, I dedicate this thesis. Pages Contents 3 List of Tables. ........................................................................................................................................................................ vi List of Abbreviations......................................................................................................................................................... vii Introduction. ........................................................................................................................................................................ -
America's Economic Way Of
|America’s Economic Way of War How did economic and financial factors determine how America waged war in the twentieth century? This important new book exposes the influence of economics and finance on the questions of whether the nation should go to war, how wars would be fought, how resources would be mobilized, and the long-term consequences for the American economy. Ranging from the Spanish–American War to the Gulf War, Hugh Rockoff explores the ways in which war can provide unique opportunities for understanding the basic principles of economics as wars produce immense changes in monetary and fiscal policy and so provide a wealth of infor- mation about how these policies actually work. He shows that wars have been more costly to the United States than most Americans realize as a substantial reliance on borrowing from the public, money creation, and other strategies to finance America’s war efforts have hidden the true cost of war. hugh rockoff is a professor of Economics at Rutgers, the State University of New Jersey, and a research associate of the National Bureau of Economic Research. His publications include numerous papers in professional journals, The Free Banking Era: A Re-examination (1975), Drastic Measures: A History of Wage and Price Controls in the United States (1984), and a textbook, History of the American Economy (2010, with Gary Walton). NEW APPROACHES TO ECONOMIC AND SOCIAL HISTORY series editors Nigel Goose, University of Hertfordshire Larry Neal, University of Illinois, Urbana-Champaign New Approaches to Economic and Social History is an important new textbook series published in association with the Economic History Society. -
British Public Perception Towards Wars in Afghanistan and Iraq
Global Regional Review (GRR) URL: http://dx.doi.org/10.31703/grr.2018(III-I).37 British Public Perception towards Wars in Afghanistan and Iraq Vol. III, No. I (2018) | Page: 503 ‒ 517 | DOI: 10.31703/grr.2018(III-I).37 p- ISSN: 2616-955X | e-ISSN: 2663-7030 | ISSN-L: 2616-955X This article seeks to explore the Aasima Safdar * Abstract perception of the British informants regarding the Afghanistan war 2001 and Iraq war Samia Manzoor † 2003. Heavy users of British media were interviewed. The present article adopts the qualitative approach Ayesha Qamar ‡ and ten in-depth interviews were conducted by the British informants. It was found that the British informants considered the 9/11 attacks as a tragic incident and Al Qaeda was held responsible for this. They supported their government’s policies to curb terrorism but they highly condemned human Key Words: causalities during the Afghanistan and Iraq wars. Particularly, they condemned their government’s Public perception, policy about Iraq war 2003. Regarding, the British British media, Iraq media coverage of these wars, there was mixed opinion. Some of them considered that British media war, Afghanistan gave biased coverage to the wars however; few war thought that media adopted a balanced approach. Overall, they stressed that the government should take responsible action against terrorism and human causalities should be avoided. Introduction September 11 attacks were immensely covered by the world media. The electronic channels reported the images of tragedy, popular personalities and the physical destructions (Monahan, 2010). Within a few hours of the tragedy, the TV screens were loaded with images of terrorist attacks.