Handbook of Public Finance General Editors: Juergen G
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The Offshore Tax Enforcement Dragnet
Emory Law Journal Volume 67 Issue 4 2018 The Offshore Tax Enforcement Dragnet Shu-Yi Oei Follow this and additional works at: https://scholarlycommons.law.emory.edu/elj Recommended Citation Shu-Yi Oei, The Offshore Tax Enforcement Dragnet, 67 Emory L. J. 655 (2018). Available at: https://scholarlycommons.law.emory.edu/elj/vol67/iss4/1 This Article is brought to you for free and open access by the Journals at Emory Law Scholarly Commons. It has been accepted for inclusion in Emory Law Journal by an authorized editor of Emory Law Scholarly Commons. For more information, please contact [email protected]. OEI GALLEYPROOFS 4/23/2018 12:07 PM THE OFFSHORE TAX ENFORCEMENT DRAGNET Shu-Yi Oei* ABSTRACT Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore financial information by financial institutions and taxpayers. Yet, while these initiatives help catch willful tax cheats, they have also adversely affected immigrants, Americans living abroad, and “accidental Americans.” This Article critiques the United States’ offshore tax enforcement initiatives, such as the Foreign Account Tax Compliant Act and the Internal Revenue Service’s offshore voluntary disclosure programs. It argues that the United States has been overly focused on two policy priorities in designing enforcement at the expense of competing considerations: First, the United States has attempted to equalize enforcement against taxpayers with solely domestic holdings and those with harder-to-detect offshore holdings by imposing harsher reporting requirements and penalties on the latter. -
Senate Bill 2198, Taxpayer Compliance Improvement Act of 1982
UNITED STATES GENERAL ACCOUNTING OFFICE - WASHINGTON, D.C. 20548 FOR RELEjhSE ON DELIVERY EXPECTED AT LO:00 &$.[*I. EST MONDAY, MARCH 22, 1982 STATEMENT OF WILLIAM J. ANDERSON, DIRECTOR, GENERAL GOVERNMENTDIVISION , BEFORE THE SUBCOMMITTEE ON OVERSIGHT OF THE INTERNAL REVENUE SERVICE OF THE SENATE COMMITTEE ON FINANCE ON ( S~~NATEBILL 2198, TAXPAYER COMPLIANCE IMPkOVEMENT ACT OF 1982 1 I 117850 Mr. Chairman and Members of the Subcommittee: We are pleased to be here today to assist your Subcommittee in considering the problem of the income tax compliance gap and the need for 5.2198, the Taxpayer Compliance Improvement Act of 1982, to help address this problem. Ourr testimony is based pri- marily on our overall experience gained from conducting audits of tax administration operations and activities over the past several years. We first addressed the issue of unreported income in July 1979 l At that time, we issued a comprehensive report in which we estimated that about 5 million individuals and couples owing about $2 billion in taxes did not file tax returns for tax year 1972, the year for which the most current data was available for analysis. We also estimated that IRS had only been able to secure delinquent returns from about 12 percent of the estimated 5 mil- lion nonfilers. Since July 1979, we have issued numerous reports and provided extensive testimony addressing IRS' &x administra- tion activities and the actions needed to improve IRS' compli- ance enforcement efforts, particularly against, the unreported income problem. We are also presently conducting several reviews of various IRS programs which are directed wholly or partially at addressing the unreported income problem. -
University of Allahabad
UNIVERSITY OF ALLAHABAD INFORMATION AND GUIDELINES FOR COMBINED RESEARCH ENTRANCE TEST (CRET) – 2018 Academic Session: 2018 - 19 SCHEDULE:The schedule of CRET-2018 has been as under: Form available Online at auadmissions.comOR Admission-2018 link of www.allduniv.ac.in Commencement of registration and submission ONLINE 22ndApril, 2018 Last date of Registration, Fee Deposition and 30th May, 2018 Form Submission ONLINE 16th May, 2018 Downloading of Admit Cards Online only 7th June, 2018 Date of Entrance Test 13th June, 2018 The University of Allahabad shall conduct COMBINED RESEARCH ENTRANCE TEST- 2018 (CRET-2018) at Allahabad for admission to the degree of Doctor of Philosophy (D.Phil.) (hereinafter referred to as D.Phil. Programme) of the University of Allahabad for the session 2018-19 in the subjects specified in SECTION 2 of this Bulletin. As laid down in the Ordinance LVI of the First Ordinance of Allahabad University (made under Section 29 of the University of Allahabad Act, 2005) candidates for admission to the degree of D. Phil. Programme must hold a Master’s degree (or a degree recognized by the University as equivalent thereto) in a relevant subject from the University, or any other University or an Institution recognized by it, and must fulfill other prescribed conditions of eligibility. Regular teachers of the University of Allahabad and of any institution maintained by it or admitted to its privileges and international Students are exempted from appearing at CRET for admission to D. Phil. Programme. All other candidates for admission to the D. Phil. Programme in the concerned subjects are required to appear at CRET-2018 after applying and register their candidature through the ONLINE APPLICATION AND REGISTRATION PROCESS at the website auadmissions.com OR Admission-2018 link of www.allduniv.ac.inand remitting the admissible Test Fee in the prescribed manner. -
Compact High Voltage Electric Power Transmission
Compact High Voltage Electric Power Transmission By Dennis Woodford, P.Eng. [email protected] January 3, 2014 Introduction There is a developing need to provide high voltage electric power transmission that minimizes impact on the environment, agriculture and communities. Overhead transmission lines have been the normal located on designated rights-of-way. Acquiring new right-of way for overhead ac transmission lines is usually challenging to permit and in some jurisdiction impossible to obtain. To minimize the adverse effects of high voltage electric power transmission lines, new technologies are forthcoming that when applied may be more acceptable. By judicious compacting of high voltage direct current (HVDC) and high voltage alternating current (HVAC) transmission systems, existing rights-of-way can be utilized, such as along roads or rail lines. A concept for compacting transmission lines for this purpose is presented. Note: Portions or all of this paper may be copied, quoted or referred to so long as Electranix Corporation is acknowledged. Electranix Corporation, 12 – 75 Scurfield Blvd, Winnipeg, MB R3Y 1G4, Canada. www.electranix.com Compacting HVDC Transmission A new technology to convert HVAC power to HVDC power and vice versa is being successfully applied throughout the world enabling use of HVDC transmission. These converters apply large power transistors in what are designated voltage sourced converters (VSC) enabling VSC transmission. One popular configuration of voltage sourced converters is termed “symmetrical monopoles.” When a converter station has two symmetrical monopoles, it is not unlike the more conventional configuration of a “bipole” which also has two poles. When a bipole is rated at ±500 kV, it has two poles, each 500 kV and grounded at one end so that the generated HVDC line voltage has one polarity positive and the other polarity negative. -
Lindahl Tax, Income Tax, Commodity Tax, and Poll Tax, a Simulation
20th International Congress on Modelling and Simulation, Adelaide, Australia, 1–6 December 2013 www.mssanz.org.au/modsim2013 Public Good Provision: Lindahl Tax, Income Tax, Commodity Tax, and Poll Tax, A Simulation T. Fukiharu School of Social Informatics, Aoyama Gakuin University Email: [email protected] Abstract: There are two traditions in the argument on taxation. On the one hand, the argument on taxation is constructed in such a way that which taxation is desirable in order to impose a tax, income tax, commodity tax or poll tax, without paying any attention on why the tax is necessary. In the partial equilibrium framework, the lump-sum tax, such as poll tax, is regarded as the best. On the other hand, it is also a tradition to assert that government imposes a tax in order to provide public goods. This paper integrates the above two traditions by constructing a primitive general equilibrium (GE) model which incorporates a public good, asking which taxation is desirable in order to impose tax, income tax, commodity tax, or poll tax to optimally provide the public good. Formally, in Part I, we start with utilizing the Lindahl mechanism to compute a Pareto-optimal public good level under a specification of the parameters on production and utility functions. The burden-sharing in this Lindahl mechanism may be regarded as a tax on the society members, while utilizing pseudo-market mechanism. We call it Lindahl tax. Next, we compute the rate of income tax in order to sustain the optimal public good level, and compare the Lindahl tax and income tax. -
The Netherls
Endogenous growth with public factors and heterogeneous human capital producers Thomas Ziesemer 93-022 .. ~ MERIT UNIVRSITY OF LIMURG P.O. BOX 616 6200 DM MASTRCHT THE NETHERLS MERIT, P.O. Box 616, 620 MD Maatricht (Netherlands) - telephone (31)43-83875- fax: (31)43-216518 ENDOGENOUS GROWTH WITH PUBLIC FACTORS AND HETEROGENEOUS * HUMAN CAPITAL PRODUCERS Thomas Ziesemer, University of Limburg, Faculty of Economics and Business Administration and Maatricht Economic Research Institute on Innovation and Technology (MERIT), P.O.Box 616, 6200 MD Maatricht, The Netherlands. Teleph: 31-43-883872, Telefax:31-43-216518, 'E-mail: T.Ziesemer~Algec.RuLimburg.NL In a growth model with no, one or multiple steady state(s) the following results are obtained for the stable steady states: If government revenues from a flat-rate income tax are spent on public factors and public factors are used for human capital production and human capital is used for the production of technical progress, then a higher rate of taxation will lead to a higher rate of technical progress. If human capital producing households have different abilities they wil have different desired (Lindahl) tax rates and a golden rule is no longer an acceptable welfare function. Therefore tax policy determines the rate of technical progress without a generally accepted welfare function. When the rate of time preference is larger than the rate of technical progress people with greater abilities want higher levels of public factors and taxes if indirect marginal utilty is inelastic with respect to net income. The outcome of this political decision wil determine the rate of technical progress. -
Paolo Silvestri Anthropology of Freedom and Tax Justice: Between Exchange and Gift
Paolo Silvestri Anthropology of Freedom and Tax Justice: between Exchange and Gift. Thoughts for an interdisciplinary research agenda1 1. Introduction The way in which fiscal institutions and fiscal policies are conceived and imple- mented raises problems at the intersection of so many ethical, institutional, legal, political and philosophical issues, both practical and theoretical, that a unified framework of all these rather fragmented issues seems to be quite impossible. Let us consider just a few of these issues. The performance of fiscal institutions is crucial for its effects on equality, inclusiveness and social mobility. Tax issues, or, rather, tax injustices are at the core, if not the origin of modern democratic and legal-political (and not only economic) institutions. The arrangement of fiscal institutions touches salient political-social issues, many of them at the heart of a sound and democratic good governance both at local and global level: transparency, accountability, efficacy, legitimacy, and trust. Last but not least, taxation is ambivalently connected to citi- zens’ trust/distrust relationships: among themselves as well as toward political, legal, and administrative institutions, since taxation is often perceived as the most immedi- ate presence (for better or for worse) of such institutions in their lives. 1 This little essay is dedicated to a great man, a man who one day gave me a great gift, rekindling my hopes for the future. At the time when I received that gift, I immediately felt an immense sense of gratitude, and an immediate boost to find ways to be able to pay my debts and honour, at my very best, the credit and trust I was given. -
1 Bus Bar, Split Bus Bar System, Special Purpose Cables. Electrical Diagram and Identification Scheme. Circuit Controlling Devic
Volume – II POWER DISTRIBUTION SYSTEM Bus Bar, split bus bar system, special purpose cables. Electrical diagram and identification scheme. Circuit controlling devices. Power utilization-typical application to avionics. Bus Bar - Introduction In most of aircrafts, the output from the generating sources is coupled to one or more low impedance conductors referred as bus bars. This are situated at central points within the aircraft and provides positive supplies to various consumer circuits. In a very simple system a bus bar can take the form of a strip of interlinked terminals while in complex system. Main bus bars are thick metal strips or rods to which input and output supply connections can be made. Bus Bar Systems Requirements: i) Power-consuming equipment must not be deprived of power in the event of power source failures. ii) Failure on the distribution system should have the minimum effect on system functioning. 1 Introduction to Avionics iii) Power consuming equipment faults must not endanger the supply of power to other equipment. Types of Consumer Services: i) Vital Services: These services are connected directly to the battery. For Example, during an emergency wheels up landing emergency lighting and crash switch operation of fire extinguishers are required. ii) Essential Services: Those are required to ensure safe flight in an in- flight emergency situation. They are connected to dc or ac bus bars. iii) Non-Essential Services: These are isolated in an in-flight emergency for load shedding purposes. Bus bar System: From the below diagram 1.1 the power supplies are 28 volts dc from engine driven generators, 115 volts 400 Hz ac from rotary inverters and 28 volts dc from batteries. -
Taxpayer First Act of 2019 R E P O R T Committee On
1 116TH CONGRESS " ! REPT. 116–39 1st Session HOUSE OF REPRESENTATIVES Part 1 TAXPAYER FIRST ACT OF 2019 R E P O R T OF THE COMMITTEE ON WAYS AND MEANS HOUSE OF REPRESENTATIVES ON H.R. 1957 [Including cost estimate of the Congressional Budget Office] APRIL 9, 2019.—Ordered to be printed VerDate Sep 11 2014 07:28 Apr 16, 2019 Jkt 089006 PO 00000 Frm 00001 Fmt 6012 Sfmt 6012 E:\HR\OC\HR039P1.XXX HR039P1 SSpencer on DSKBBXCHB2PROD with REPORTS E:\Seals\Congress.#13 TAXPAYER FIRST ACT OF 2019 VerDate Sep 11 2014 07:28 Apr 16, 2019 Jkt 089006 PO 00000 Frm 00002 Fmt 6019 Sfmt 6019 E:\HR\OC\HR039P1.XXX HR039P1 SSpencer on DSKBBXCHB2PROD with REPORTS with DSKBBXCHB2PROD on SSpencer 1 116TH CONGRESS " ! REPT. 116–39 1st Session HOUSE OF REPRESENTATIVES Part 1 TAXPAYER FIRST ACT OF 2019 R E P O R T OF THE COMMITTEE ON WAYS AND MEANS HOUSE OF REPRESENTATIVES ON H.R. 1957 [Including cost estimate of the Congressional Budget Office] APRIL 9, 2019.—Ordered to be printed U.S. GOVERNMENT PUBLISHING OFFICE 89–006 WASHINGTON : 2019 VerDate Sep 11 2014 07:28 Apr 16, 2019 Jkt 089006 PO 00000 Frm 00003 Fmt 4012 Sfmt 4012 E:\HR\OC\HR039P1.XXX HR039P1 SSpencer on DSKBBXCHB2PROD with REPORTS E:\Seals\Congress.#13 VerDate Sep 11 2014 07:28 Apr 16, 2019 Jkt 089006 PO 00000 Frm 00004 Fmt 4012 Sfmt 4012 E:\HR\OC\HR039P1.XXX HR039P1 SSpencer on DSKBBXCHB2PROD with REPORTS C O N T E N T S Page I. -
US, Qatar Commit to Advance High-Level Strategic Co-Operation
COMMUNITY | Page 16 QATAR | Page 7 South African cancer survivor says she owes it to Qatar New system to improve for saving life training standards in driving schools published in QATAR since 1978 WEDNESDAY Vol. XXXX No. 11240 July 10, 2019 Dhul Qa’dah 7, 1440 AH GULF TIMES www. gulf-times.com 2 Riyals US, Qatar commit to advance high-level strategic co-operation His Highness the Amir Sheikh Tamim bin Hamad al-Thani with US President Donald His Highness the Amir Sheikh Tamim bin Hamad al-Thani and US President Donald Trump attending the working lunch at the White House yesterday. Trump meeting at the White House yesterday. O Amir meets US President at the White House O Several agreements and MoUs signed in the fields of trade, investment and defence O Trump highlights role of Al Udeid Air Base QNA world, hailing Qatar’s large invest- the desire to multiply this fi gure for his planes and Gulfstream Aviation. Washington ments in the United States and the huge confi dence in the US economy. They also witnessed the signing of an agreements which will be signed later The Amir extended an invitation to agreement in the fi eld of air defence to in the day in the fi elds of trade, invest- the US president to visit Qatar and Al provide Qatar with multiple additional is Highness the Amir Sheikh ment and defence. Udeid Air Base. systems of air defence. Tamim bin Hamad al-Thani Trump highlighted the role of Al President Trump thanked the Amir The signing ceremony was attended Hand the President of the United Udeid Air Base and its strategic impor- for the invitation, and praised the by members of the offi cial delegation States of America Donald Trump dis- tance in the Middle East, terming it as achievements made by Qatar at Al accompanying the Amir. -
Investors' Reaction to a Reform of Corporate Income Taxation
Investors' Reaction to a Reform of Corporate Income Taxation Dennis Voeller z (University of Mannheim) Jens M¨uller z (University of Graz) Draft: November 2011 Abstract: This paper investigates the stock market response to the corporate tax reform in Germany of 2008. The reform included a decrease in the statutary corporate income tax rate from 25% to 15% and a considerable reduction of interest taxation at the shareholder level. As a result, it provided for a higher tax benefit of debt. As it comprises changes in corporate taxation as well as the introduction of a final withholding tax on capital income, the German tax reform act of 2008 allows for a joint consideration of investors' reactions on both changes in corporate and personal income taxes. Analyzing company returns around fifteen events in 2006 and 2007 which mark important steps in the legislatory process preceding the passage of the reform, the study provides evidence on whether investors expect a reduction in their respective tax burden. Especially, it considers differences in investors' reactions depending on the financial structure of a company. While no significant average market reactions can be observed, the results suggest positive price reactions of highly levered companies. Keywords: Tax Reform, Corporate Income Tax, Stock Market Reaction JEL Classification: G30, G32, H25, H32 z University of Mannheim, Schloss Ostfl¨ugel,D-68161 Mannheim, Germany, [email protected]. z University of Graz, Universit¨atsstraße15, A-8010 Graz, Austria, [email protected]. 1 Introduction Previous literature provides evidence that companies adjust their capital structure as a response to changes in the tax treatment of different sources of finance. -
An Optimal Benefit-Based Corporate Income
An optimal benefit-based corporate income tax Simon Naitram∗ June 2020 Abstract In this paper I explore the features of a benefit-based corporate income tax. Benefit-based taxation defines a firm’s fair share of tax as the returns to the public input. When the government is constrained to fund the public input through the use of a distortionary tax on the firm’s profit, the optimal benefit-based corporate income tax rate is a function of three estimable elasticities: the direct public input elasticity of profit, the indirect public input elasticity of profit, and the (net of) tax elasticity of profit. Using public capital as a measure of the public input, I calculate optimal benefit-based tax rates. Under plausible parameters, these optimal tax rates are quantitatively reasonable and are progressive. I show that benefit-based taxation delivers inter-nation equity. JEL: H21; H25; H32; H41 Keywords: benefit-based taxation; optimal corporate tax; public input 1 Introduction There is no consensus on the purpose of the corporate income tax. This lack of consensus on the purpose of the tax makes it almost impossible to agree on the design of the corporate tax system. Without guidelines on what we are trying to achieve, how do we assess any proposal for corporate tax reform? This concern is expressed most clearly by Weisbach(2015): \The basic point is that we cannot know what the optimal pattern of international capital income taxation should be without understanding the reasons for taxing capital income in the first place... To understand the design of firm-level taxation, however, we need to know why we are taxing firms.” ∗Adam Smith Business School, University of Glasgow and Department of Economics, University of the West Indies, Cave Hill, St Michael, Barbados.