The Future of Personal Wealth and Inheritance Taxation in Norway
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Marxist Crisis Theory and the Severity of the Current Economic Crisis
Marxist Crisis Theory and the Severity of the Current Economic Crisis By David M. Kotz Department of Economics Thompson Hall University of Massachusetts Amherst Amherst, MA 01003, U.S.A. December, 2009 Email Address: [email protected] This paper was presented on a panel on "Heterodox Analyses of the Current Economic Crisis" sponsored by the Union for Radical Political Economics at the Allied Social Science Associations annual convention, Atlanta, January 4, 2010. Research Assistance was provided by Ann Werboff. It is a revised version of a paper "The Final Crisis: What Can Cause a System-Threatening Crisis of Capitalism," Science & Society 74(3), July 2010. Marxist Crisis Theory and the Current Crisis, December, 2009 1 The theory of economic crisis has long occupied an important place in Marxist theory. One reason is the belief that a severe economic crisis can play a key role in the supersession of capitalism and the transition to socialism. Some early Marxist writers sought to develop a breakdown theory of economic crisis, in which an absolute barrier is identified to the reproduction of capitalism.1 However, one need not follow such a mechanistic approach to regard economic crisis as central to the problem of transition to socialism. It seems highly plausible that a severe and long-lasting crisis of accumulation would create conditions that are potentially favorable for a transition, although such a crisis is no guarantee of that outcome.2 Marxist analysts generally agree that capitalism produces two qualitatively different kinds of economic crisis. One is the periodic business cycle recession, which is resolved after a relatively short period by the normal mechanisms of a capitalist economy, although since World War II government monetary and fiscal policy have often been employed to speed the end of the recession. -
2015 FOX Fall Forum
2015 FOX Fall Forum FOX 100 Resource Center A Roundup of Leading Industry Knowledge amily Office Exchange (FOX) is pleased to present this year’s F selection of articles, reports and white papers devoted to the issues of most concern to wealth owners and family office executives globally. To assist in locating information of particular interest, Resource Center material once again is grouped by subject area: • Trusts, Tax and Estate Planning Page 2 • Security, Technology, Family Office Page 4 and Lifestyle Issues • Family Matters (Legacy Planning) Page 9 • Investment Page 11 • Family Office Issues Page 17 Soon after the conclusion of the Fall Forum unless noted as “print only” all Resource Center material will be available at: https://www.familyoffice.com/learning-events/forums/2015-fox-100 Presented in the Grand Foyer Lobby, JW Marriott 1 2015 FOX Fall Forum TRUSTS, TAX AND ESTATE APPLICATION OF THE 2-PERCENT FLOOR TO TRUST AND ESTATE EXPENSES PLANNING McGladrey LLP Though the IRS issued the final regulations for INBOUND WEALTH PLANNING FOR THE section 67 in May 2014 to require the GLOBAL FAMILY unbundling of a fiduciary's integrated fee, Northern Trust corporate fiduciaries and tax planners continue Determining exactly whose income, gains and to struggle with designing and implementing assets is subject to the U.S. Federal tax system procedures to ensure that the directive is is a daunting inquiry that requires a properly accounted for on returns during the comprehensive approach without shortcuts. upcoming tax filing season. And, just when the general rules of international tax principles under the Internal Revenue Code While most corporate fiduciaries have moved on (the Code) and related treasury regulations have to the task of applying the regulations to their been reviewed and applied, an applicable trusts and estates, some commentators still international tax treaty or a new tax law can contend that the regulations misinterpret the change everything. -
Copyrighted Material
PART 1 The World Property Market – A Beginner’s Guide There is no shortage of ‘experts’ when it comes to investing in prop- erty. Nearly everyone, everywhere, who bought property a decade ago is sitting on a unprecedented pile of ‘dough’. Nominally, that is, of course, because property profi t is notional until we cash in our chips. This ‘success’ has gone to our heads, while few of us did anything very clever to achieve this paper wealth. For the most part, we just rode the wave that swept us further and further up the profi t curve. While not many people remember the last property collapse, though 2007–8 may refresh some memories many more are still nursing losses from the stock market collapse that followed the ‘Dot Com’ bubble burst. The ‘expert’ investors who rode that wave up have discovered two important facts: what goes up a long way fast can come down just as dramatically; and that they had either forgotten or never really knew the fundamentals that underpin long-term share prices. Now, there are no absolute guarantees with any investment, except that your chances of success are improved exponentially if you understand something ofCOPYRIGHTED the forces at work in the market MATERIAL – in this case, the property market. If you really are an expert and your property investments have outperformed the general trend, then skip this chapter. If not, read on. Property – the backbone of wealth creation Property has been a worthwhile source of wealth for generations. More private individuals have become millionaires in this way than 10 PART 1 THE WORLD PROPERTY MARKET – A BEGINNER’S GUIDE by any other route to wealth. -
Explanation of Proposed Estate and Gift Tax Treaty Between the United States and the Kingdom of Denmark
[JOINT COMMITTEE PRINT] EXPLANATION OF PROPOSED ESTATE AND GIFT TAX TREATY BETWEEN THE UNITED STATES AND THE KINGDOM OF DENMARK SCHEDULED FOR A HEARING BEFORE THE COMMITTEE ON FOREIGN RELATIONS UNITED STATES SENATE ON APRIL 26, 1984 PREPARED BY THE STAFF OF THE JOINT COMMITTEE ON TAXATION APRIL 25, 1984 U .S. GOVERNMENT PRINTING OFFICE 33-7070 WASHINGTON: 1984 JCS-18-84 CONTENTS Page [NTRODUCTION .......................... ...................... ........................... .......... 1 1. SUMMARy..... ..... ........................................................................... 3 II. OVERVIEW OF UNITED STATES TAXATION OF INTERNATION- AL GRATUITOUS TRANSFERS AND TAX TREATIES ................ A. United States Estate and Gift Tax Rules ... ............. B. Causes of Double Taxation ......................... .. .. ............ C. United States Estate and Gift Tax Treaties ........ .. .. III. EXPLANATION OF PROPOSED TAX TREATy................................ 11 Article 1. Personal Scope........ .... .. ........... ...................... ... 11 Article 2. Taxes Covered...... ......... .... ............................... 11 Article 3. General Definitions.... ......................... ............. 12 Article 4. Fiscal Domicile ................................................. 13 Article 5. Real Property..... .. ............................................. 14 Article 6. Business Property of a Permanent Estab- lishment and Assets Pertaining to a Fixed Based Used for the Performance of Independent Person- al Services...... ................. -
International Tax Planning and Reporting Requirements
international tax planning and reporting requirements Foreign earned income exclusions and foreign tax credits can significantly reduce the U.S. tax liability incurred on foreign- source income and help to avoid double taxation. Complex reporting is required for U.S. persons owning foreign assets including bank accounts and other financial investments. 106 NEW IN 2018 filed electronically. It is due April 17, 2018 and can be extended. Reportable transactions between the U.S. LLC and its foreign The Tax Cuts and Jobs Act of 2017 will have a significant impact owner include contributions and distributions between the two, in the international tax arena. Most notably, there is a manda- and would certainly include the setup and closure of the LLC. 2018 personal tax guide tory one-time repatriation of offshore foreign earnings held in There are onerus penalties for non-filing. a specified foreign entity. All U.S. shareholders with at least 10% ownership in a specified foreign entity are required to include EisnerAmper their share of the offshore earnings and profits which have not FOREIGN TAX ISSUES previously been taxed in the U.S. Only a portion of the foreign earnings are taxable based on the applicable percentage. U.S. Multinational clients with cross-border income from employ- shareholders will be allowed a 77.1% deduction for non-cash ment and investments are in today’s mainstream. Many taxpayers amounts and a 55.7% reduction for cash amounts. The effec- are discovering that they are subject to taxation and/or report- tive tax rate will ultimately depend on the U.S. -
2021 Tax Rates, Schedules, and Contribution Limits
2021 tax rates, schedules, and contribution limits Income tax Tax on capital gains and qualified dividends If taxable Income income But Of the Single Married/Filing jointly/Qualifying Widow(er) Tax rate is over not over The tax is amount over $0–$40,400 $0–$80,800 0% Married/Filing $0 $19,900 $0.00 + 10% $0 jointly and $19,900 $81,050 $1,990 + 12% $19,900 Over $40,400 but not Over $80,800 but not over qualifying over $445,850 $501,600 15% widow(er)s $81,050 $172,750 $9,328 + 22% $81,050 Over $445,850 Over $501,600 20% $172,750 $329,850 $29,502 + 24% $172,750 Additional 3.8% federal net investment income (NII) tax applies to individuals $329,850 $418,850 $67,206 + 32% $329,850 on the lesser of NII or modified AGI in excess of $200,000 (single) or $250,000 $418,850 $628,300 $95,686 + 35% $418,850 (married/filing jointly and qualifying widow(er)s). Also applies to any trust or $628,300 $168,993.50 + 37% $628,300 estate on the lesser of undistributed NII or AGI in excess of the dollar amount Single $0 $9,950 $0.00 + 10% $0 at which the estate/trust pays income taxes at the highest rate ($13,050). $9,950 $40,525 $995 + 12% $9,950 Kiddie tax* $40,525 $86,375 $4,664 + 22% $40,525 Child’s unearned income above $2,200 is generally subject to taxation at $86,375 $164,925 $14,751 + 24% $86,375 the parent’s marginal tax rate; unearned income above $1,100 but not $164,925 $209,425 $33,603 + 32% $164,925 more than $2,200 is taxed at the child’s tax rate. -
Forbes Insights: 2014 BNP Paribas Individual Philanthropy Index
2014 BNP PariBas iNdividual PhilaNthroPy iNdex PHILANTHROPiC JOURNEYS: THE iMPORTANCe oF TIMiNG MEASURING COMMITMENT IN EUROPE | ASIA | USA | MIDDLE EAST CoNteNts Key Findings.............................................................................................................................................................2 2014 BNP Paribas Individual Philanthropy Index ...................................................................................... 4 Discussion of Index Results ............................................................................................................................... 6 Comparisons to 2013 Results ............................................................................................................................7 Projected Giving: The Giving Pledge ............................................................................................................. 8 If Not Now, When? ............................................................................................................................................... 9 Urgency—Profile: To Stop the Suffering .....................................................................................................17 The Philanthropic Journey, Stage One: Motivation .................................................................................18 The Philanthropic Journey, Stage Two: The State of Wealth .............................................................20 The Philanthropic Journey, Profile: A Thousand Fires ..........................................................................23 -
Ten Years Without the Swedish Inheritance Tax – Mourned by No
www.svensktnaringsliv.se DECEMBER 2015 Storgatan 19, 114 82 Stockholm Phone: +46 8 553 430 00 ANDERS YDSTEDT, AMANDA WOLLSTAD Ten years without the Swedish inheritance tax Mourned by no one – missed by few Arkitektkopia AB, Bromma, 2015 Arkitektkopia It is ten year since the Swedish inheritance tax was abolished by a unanimous riksdag (parlia- ment). How did it happen? How come all political parties in parliament – from the conservative right to the socialist left – agreed on its demise? This book tells the history of the tax, its abolishment and what consequences it had on Swedish business owners and Swedish business. It also takes a broader perspective and looks out to Europe and the world, proving that Sweden is far from as alone in refraining from taxing inheritance as we are sometimes led to believe. The abolishment of inheritance and gift tax marked the start of a broader debate on ownership issues in Sweden, a debate that eventually led to the abolishment of wealth tax and a more reasonable taxation of owner led corporations. The fact that it was the inheritance and gift tax that managed to gather both politicians and the industry around a common goal says a thing or two about which consequences the taxation had on Swedish wealth and business. The authors: Anders Ydstedt is an advisor, entrepreneur and author. He has previously written about genera- tional shifts in family businesses, the road to lower taxes and the Swedish chapter in Taxation in Europe – IREF Yearbook 2013 Amanda Wollstad is an editorial writer and public affairs consultant. -
Estate and Gift Tax, Federal 125
Estate and gift tax, federal 125 Estate and gift tax, federal A third objective is a reduction in wealth con- centration. By taxing the wealth holdings of the David Joulfaian wealthiest estates, the estate and gift taxes are ex- Department of the Treasury pected to reduce the size of bequests, reducing the wealth accumulated over generations. This is also The federal tax treatment of wealth transferred accomplished by subjecting capital income that has in contemplation of, or at the time of, death. escaped the personal income tax to estate taxation. Another objective is taxation of each genera- tion’s wealth. Wealth transfers to grandchildren are The estate and gift tax is the only wealth tax levied taxed under the estate and gift taxes. However, be- by the federal government. The estate tax was first cause of the emphasis on taxing each generation, an enacted in 1916 and applied to the wealth of dece- additional tax—the GSTT—is also levied on these dents with estates in excess of $50,000. It has un- transfers. The rationale for the GSTT is that a tax dergone numerous changes, especially in 1976 and should be levied on wealth transfers to children, 1981, and it currently applies to taxable estates in coupled with another tax when they, in turn, transfer excess of $600,000, with a maximum tax rate of wealth to their children. 55 percent. To minimize state objections to the enactment The gift tax was first enacted in 1924, repealed of death taxes by the federal government, the estate in 1926, and reenacted in 1932 in an attempt to re- tax provides a tax credit for state death taxes, duce estate tax avoidance via the initiation of inter thereby keeping the state tax base intact. -
Does Canada Need a Wealth Tax?
2020 DOES CANADA NEED A WEALTH TAX? Philip Cross 2020 Fraser Institute Does Canada Need a Wealth Tax? by Philip Cross Contents Executive Summary / i 1 Introduction / 1 2 Different views of wealth in economics / 4 3 Canada’s wealth more equally distributed / 6 4 Wealth taxes generate little net revenue / 13 5 Wealth is hard to define and measure / 19 6 Macro issues—a wealth tax discourages savings and investments, and lowers long-term growth / 25 7 Fairness and social issues / 30 Conclusion / 35 References / 36 About the Author / 41 Publishing Information / 42 About the Fraser Institute / 43 Purpose, Funding, and Independence / 43 Peer review —validating the accuracy of our research / 44 Editorial Advisory Board / 44 fraserinstitute.org Cross • Does Canada Need a Wealth Tax? • i Executive Summary In its recent Speech from the Throne, the federal government said it was considering a tax on what it termed “extreme wealth inequality” in this country. This would be a mis- take for several reasons. To start, wealth inequality is not increasing in Canada. Statistics Canada data show that wealth held by the lowest three income quintiles rose more than that held by the highest two quintiles, raising their share of wealth from 27.1% in 2010 to 29.5% in 2019. The gain in wealth for those with lower incomes reflects increases for both financial and non-financial assets, and began before Canada’s housing market took off in 2015. Canada’s middle class holds more financial assets than the middle class in the United States and, therefore, is less vulnerable to a downturn in the housing market. -
Taxation of Partnerships - Legal General Report for the Nordic Tax Research Council´S Annual Meeting on 22 May 2015 in Aarhus
Nordic Tax J. 2015 2:47–56 Report Open Access Liselotte Madsen Taxation of Partnerships - Legal general report for the Nordic Tax Research Council´s annual meeting on 22 May 2015 in Aarhus DOI 10.1515/ntaxj-2015-0005 though the similar Norwegian word is “utdeling”, and so Received Sep 08, 2015; accepted Sep 18, 2015 on. In English translation, the word “distribution” is used. I hope that it does not provide any linguistic challenges. The term partnership is used to the extent that it is not found necessary to indicate the national name, and ex- 1 Introduction and terminology presses only that it is a transparent business. First, a short review of the company law rules regard- This report has been written on the basis of a number of ing the establishment of partnerships will be carried out, Nordic national reports on the subject: Taxation of part- after which, the tax rules will be reviewed. nerships. The contributions from Denmark, Norway, Swe- den, and Iceland have been incorporated in the report to the best of my ability and by relevance. 2 Company law matters The term "partnership" is a general term for a num- ber of companies that have a common characteristic - First, it is relevant to relate to the company law rules ap- namely that they are not taxable entities, but rather trans- plicable to partnerships. A description of this has been parent for tax purposes. The company type, partnership, deemed important for the understanding of the civil law which is not a separate tax subject, can be found in all rules for partnerships, both in relation to the third parties the Nordic countries. -
Wealth Distribution and Taxation in EU Members
ISSN 1725-7565 (PDF) ISSN 1725-7557 (Printed) TAXATION PAPERS Wealth WORKING PAPER N. 60 – 2015 distribution Anna Iara (European Commission) and taxation in EU Members Taxation and Customs Union Taxation Papers are written by the staff of the European Commission’s Directorate-General for Taxation and Customs Union, or by experts working in association with them. Taxation Papers are intended to increase awareness of the work being done by the staff and to seek comments and suggestions for further analyses. These papers often represent preliminary work, circulated to encourage discussion and comment. Citation and use of such a paper should take into account of its provisional character. The views expressed in the Taxation Papers are solely those of the authors and do not necessarily reflect the views of the European Commission. Comments and inquiries should be addressed to: TAXUD [email protected] Cover photo made by Milan Pein Despite all our efforts, we have not yet succeeded in identifying the authors and rights holders for some of the images. If you believe that you may be a rights holder, we invite you to contact the Central Audiovisual Library of the European Commission. This paper is available in English only. Europe Direct is a service to help you find answers to your questions about the European Union Freephone number: 00 800 6 7 8 9 10 11 A great deal of additional information on the European Union is available on the Internet. It can be accessed through EUROPA at: http://europa.eu. For information on EU tax policy visit the European Commission’s website at: http://ec.europa.eu/taxation_customs/taxation/index_en.htm Do you want to remain informed of EU tax and customs initiatives? Subscribe now to the Commission’s e-mail newsflash at: http://ec.europa.eu/taxation_customs/common/newsflash/index_en.htm Cataloguing data can be found at the end of this publication.