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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. -
Misc Publications MP-02
TAX FOUNDATION, INC. 50 Rockefeller Plaz a New York, N. Y. August 15, 1940 1 FORMM This conrpilation and bibliography are presented in th e hone that they will contribute to a fuller understanding of a difficult and at times controversial subject . In selecting the materials included an effort was made to obtain a cross section of opinions cnnd points of view . Attention is directed to the bibliograpay of periodical and special materials on war, profit s and excess profits thxation issued from 1916 to 1940. In the light of recent event s, the body of literature developed as P. result of our experience with those forms of taxation during and immodiately after the War of 1914--1919 has assumed anew significance . August 15, 1940 xA FOUIMATION 0 At Page Current Proposals 1 Some Aspects of the Profit-Tax Bill 2 The Excess-Profits Tart 3 Taxation and National Defense 4 Holding Up Defense 5 Excess-Profit Tax Hinges on Business 6 The Revenue Angle 7 The Basis 11or An Excess-Profits Tax 9 The Valuation cf Business Investments 9 Effects of Excess Profits Taxes 1 0 Excess Profits Tax : A Wartime Measure 11 Excess Profits Taxes, 1933 o 1940 1 2 The World War and Postwar Pederal :Taxation 1 3 Wartime Taxes on Profits 14 LIST OF TABLE S National Defense Expenditures, Fiscal Years 1928-1941 15 Taxes, Not Income and Dividends of All Activ e Corporations in the United States 16 Effects of Tax Increases 1 7 Table Showing 7,899 Representative Corporations Classified According to Amount of Invested Capital and R :titio of Net Income to Invested Capital During tho Taxable Year 18 Excess-Profits Taxes of Twelve Coal Companies 19 BIBLIOGRAPHY :Bibliographer on Par Profits and Excoss Profits Taxos 20 1 . -
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. ........................................................................................................................................................................ -
How Complexity Anticipates Black Swans – the 2020 Market Crash
How Complexity Anticipates Black Swans – the 2020 Market Crash. April, 26th 2020 The 2020 stock market crash was a global stock market crash that began on 20 February 2020. On 12 February, the Dow Jones Industrial Average, the NASDAQ Composite, and S&P 500 Index all finished at record highs (while the NASDAQ and S&P 500 reached subsequent record highs on 19 February). From 24 to 28 February, stock markets worldwide reported their largest one-week declines since the 2008 financial crisis, thus entering a correction. Global markets into early March became extremely volatile, with large swings occurring in global markets. On 9 March, most global markets reported severe contractions, mainly in response to the COVID-19 pandemic and an oil price war between Russia and the OPEC countries led by Saudi Arabia. This became colloquially known as Black Monday. At the time, it was the worst drop since the Great Recession in 2008. During March 2020, global stocks saw a downturn of at least 25%, and 30% in most G20 nations. Complexity tends to peak, or increases rapidly, prior to a crisis. Financial markets are no exception. We have devised new complexity-based indices for anticipating Black Swans. One such index, which we call C3, has worked egregiously in major European markets, offering early warnings ranging from 40 to 220 hours before the February 2020 collapse. Below are the charts of the said indices together with the corresponding C3 index. The dashed red line indicates when C3 peaks, triggering a shorting signal, while the blue dashed line coincides with the commencing of the downfall. -
Stuyvesant Student Opportunity Bulletin #37L June 11, 2021
Stuyvesant Student Opportunity Bulletin #37L June 11, 2021 Please note that in this “Long” version of the Student Opportunity Bulletin, all opportunities in each category are included. For the list of only the New and Deadline Approaching opportunities in each category, you may click & open the “Short” version of the Student Opportunity document you received. CATEGORY TABLE OF CONTENTS: (Download this entire PDF document in order to use the following links to jump to your area(s) of interest) 1. EVENTS OF INTEREST TO STUDENTS 2. ACADEMIC PROGRAMS 3. BUSINESS & JOBS 4. COMMUNITY SERVICE 5. LEADERSHIP, GOVERNMENT, LAW, ADVOCACY, INTERNATIONAL 1 6. MUSEUMS & ART 7. PARKS, ZOOS, & NATURE 8. STEM OPPORTUNITIES a. ENGINEERING / MATH / COMPUTER SCIENCE b. MEDICAL / LIFE SCIENCES 9. THEATER, WRITING, MUSIC, PERFORMING ARTS, VIDEO 10. CONTESTS & COMPETITIONS 11. OPPORTUNITY LISTS AND RESOURCES 12. SCHOLARSHIPS This edition includes some new events & opportunities in most of the sections below– many have deadlines coming up in the next week or two- so please explore them ASAP. For example: --In the ACADEMICS section, there is a free summer STEP/STEM program offered by Vaughn College of Aeronautics – it is targeted for low-income 2 students or those from under-represented groups, but all may apply – the deadline to do so is Monday, June 14! And today is the application deadline for free summer classes with the TGR Foundation and The BMCC College Now Program. --In the BUSINESS/JOBS section, there are deadlines this week for several virtual Internship Programs, a personal financial literacy program for high school students, a virtual Career Day, and a free summer Externship Program covering development of business knowledge & skills offered by AT&T. -
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. -
The Federal Definition of Tax Partnership
Brooklyn Law School BrooklynWorks Faculty Scholarship Winter 2006 The edeF ral Definition of Tax Partnership Bradley T. Borden [email protected] Follow this and additional works at: https://brooklynworks.brooklaw.edu/faculty Part of the Other Law Commons, Taxation-Federal Commons, and the Tax Law Commons Recommended Citation 43 Hous. L. Rev. 925 (2006-2007) This Article is brought to you for free and open access by BrooklynWorks. It has been accepted for inclusion in Faculty Scholarship by an authorized administrator of BrooklynWorks. ARTICLE THE FEDERAL DEFINITION OF TAX PARTNERSHIP Bradley T. Borden* TABLE OF CONTENTS I. INTRODU CTION ...................................................................... 927 II. THE DEFINITIONS OF MULTIMEMBER TAx ENTITIES ............ 933 A. The EstablishedDefinitions .......................................... 933 B. The Open Definition: Tax Partnership......................... 936 III. HISTORY AND PURPOSE OF PARTNERSHIP TAXATION ............ 941 A. The Effort to Disregard................................................. 941 B. The Imposition of Tax Reporting Requirements ........... 943 C. The Statutory Definition of Tax Partnership............... 946 D. The 1954 Code: An Amalgam of the Entity and Aggregate Theories........................................................ 948 E. The Section 704(b) Allocation Rules and Assignment of Incom e ....................................................................... 951 F. The Anti-Abuse Rules .................................................... 956 * Associate Professor of Law, Washburn University School of Law, Topeka, Kansas; LL.M. and J.D., University of Florida Levin College of Law; M.B.A. and B.B.A., Idaho State University. I thank Steven A. Bank, Stanley L. Blend, Terrence F. Cuff, Steven Dean, Alex Glashausser, Christopher Hanna, Brant J. Hellwig, Dennis R. Honabach, Erik M. Jensen, L. Ali Khan, Martin J. McMahon, Jr., Stephen W. Mazza, William G. Merkel, Robert J. Rhee, William Rich, and Ira B. -
County of Santa Clara COVID-19 Vaccination Plan
s COVID-19 VACCINATION PLAN Santa Clara County Revised on Date: 12/8/20 Original Version Submitted: 12/1/20 Santa Clara County Public Health Department [email protected] [JURISDICTION] COVID-19 VACCINATION PLAN Table of Contents Introduction/Explanation .............................................................................................................................. 2 Section 1: COVID-19 Vaccination Preparedness Planning ........................................................................... 3 Section 2: COVID-19 Organizational Structure and Partner Involvement .................................................... 8 Section 3: Phased Approach to COVID-19 Vaccination ................................................................................. 9 Section 4: Critical Populations .................................................................................................................... 10 Section 5: COVID-19 Provider Recruitment and Enrollment ...................................................................... 11 Section 6: Vaccine Administration Capacity ............................................................................................... 13 Section 7: COVID-19 Vaccine Allocation, Ordering, Distribution and Inventory Management ................. 16 Section 8: COVID-19 Vaccine Storage and Handling .................................................................................. 17 Section 9: COVID-19 Vaccine Administration Documentation and Reporting .......................................... -
Issue Full File
JOURNAL OF RESEARCH IN B USINESS VOLUME • BAND • CİLT: 6 / ISSUE • AUSGABE • SAYI: 1 JUNE • JUNI • HAZİRAN 2021 / E-ISSN: 2630-6255 PUBLISHED IN ENGLISH, GERMAN & TURKISH Journal of Research in Business: Volume • Band • Cilt: 6 / Issue • Ausgabe • Sayı: 1 June • Juni • Haziran: 2021 Biannual Peer-Reviewed Academic Journal / Halbjährliches, von Experten begutachtetes akademisches Journal 6 Aylık Hakemli Akademik Dergi E-ISSN: 2630-6255 Owner • Inhaber • Marmara Üniversitesi Rektörlüğü Adına İmtiyaz Sahibi Prof. Dr. Erol ÖZVAR (Rector • Rektor • Rektör) Owner of the Journal • Inhaber • Derginin Sahibi On behalf of Marmara University Faculty of Business Administration, M. Ü. İşletme Fakültesi adına Prof. Dr. Hakan YILDIRIM (Dean • Dekan • Dekan) Editorial Board • Redaktionsleitung • Yayın Kurulu/ Editors • Redaktoren • Editörler Dr. Öğr. Üyesi Selçuk KIRAN, Marmara Üniversitesi, Editor-in-Chief • Chefredakteur • Baş Editör Dr. Öğr. Üyesi N. Ozan BAKIR, Marmara Üniversitesi, Editor • Redakteur • Editör Arş. Gör. İlkim Ecem EMRE, Marmara Üniversitesi, Asst. Editor • Redaktionsassistent • Editör Yrd. Arş. Gör. Gizem Eda GÜLOZ, Marmara Üniversitesi, Asst. Editor • Redaktionsassistent • Editör Yrd. Arş. Gör. Alperen YASA, Marmara Üniversitesi, Asst. Editor • Redaktionsassistent • Editör Yrd. Advisory Board • Beratungsausschuss • Danışma Kurulu M. Emin ARAT, Fenerbahçe University | Turkey Jur. Bert EICHHORN, SRH Hochschule Berlin | Germany Serra YURTKORU, Marmara University | Turkey Graham GAL, University of Massachusetts | USA Jean Pierre GARITTE, -
IS U.S. GOVERNMENT DEBT DIFFERENT? I
IS U.S. GOVERNMENT DEBT DIFFERENT? i IS U.S. GOVERNMENT DEBT DIFFERENT? ii iii IS U.S. GOVERNMENT DEBT DIFFERENT? EDITED BY Franklin Allen Anna Gelpern Charles Mooney David Skeel AUTHORS Donald S. Bernstein William W. Bratton Peter R. Fisher Richard J. Herring James R. Hines Jr. Howell E. Jackson Jeremy Kreisberg James Kwak Deborah Lucas Michael W. McConnell Jim Millstein Charles W. Mooney Jr. Kelley O’Mara Zoltan Pozsar Steven L. Schwarcz Richard Squire Richard Sylla FIC Press Philadelphia, USA iv Published by FIC Press 2405 Steinberg Hall - Dietrich Hall 3620 Locust Walk Philadelphia, PA 19104-6367 USA First Published 2012 ISBN 978-0-9836469-9-0 (paperback) ISBN 978-0-9836469-8-3 (e-book version) Cover artwork, design and layout by Christopher Trollen v Contents The Contributors ix Acknowledgments xxi PREFACE xxiii by Anna Gelpern 1 U.S. Government Debt Has Always Been Different! 1 Richard Sylla 2 A World Without Treasuries? 13 William W. Bratton 3 Default and the International Role of the Dollar 21 Richard J. Herring 4 A Macro View of Shadow Banking: Do T-Bill Shortages Pose a New Triffin Dilemma? 35 Zoltan Pozsar 5 Origins of the Fiscal Constitution 45 Michael W. McConnell 6 The 2011 ebtD Ceiling Impasse Revisited 55 Howell E. Jackson 7 A Market for End-of-the-World Insurance? Credit Default Swaps on US Government Debt 69 Richard Squire vi Contents 8 Thoughts on ebtD Sustainability: Supply and Demand Keynote Remarks 87 Peter R. Fisher 9 The ederalF Debt: Assessing the Capacity to Pay 101 Deborah Lucas 10 TheTax Revenue Capacity of the U.S. -
March/April 2018 Ιαμ Ινφινιτυ
MARCH/APRIL 2018 ΙΑΜ ΙΝΦΙΝΙΤΥ 1 ΑΞΙΟΝ ΕΣΤΙΝ MARCH/APRIL 2018 ΙΑΜ ΙΝΦΙΝΙΤΥ About Us IAM – Inφinity Astrological Magazine is a bimonthly online magazine that was born in 2015, in Kikinda, Serbia and was reborn in 2017, in Athens, Greece. IAM is for professionals astrologers, students of astrology and for all astrology lovers. Serbian astrologer Smiljana Gavrančić is the founding editor and owner of IAM. She specialises in exploring significant degrees in Mundane Astrology and her writings have appeared in the Astrological Journal, in The Mountain Astrologer blog and in ISAR‘s International Astrologer. As of November 2016, all issues of IAM have become part of Alexandria iBase Project, a digital astrological database and as of March 2017 articles in IAM are featured regularly on astro.com in the section ’’Understanding Astrology’’ along with The Astrological Journal and The Mountain Astrologer. IAM is associated with most relevant schools, journals and people in the astrological field. Victor Olliver (associate from The Astrological Journal, The Astrological Association GB) Tem Tarriktar (associate from The Mountain Astrologer) Frank C. Cllifford (associate from the London School of Astrology) Sharon Knight (associate from APAI) Wendy Stacey (associate from Mayo School of Astrology and The Astrological Association GB) Jadranka Ćoić (associate from The Astrological Lodge of London) Mandi Lockley (associate from Academy of Astrology UK). Special members are Melanie Reinhart (The Faculty Of Astrological Studies), Roy Gillett (the president of The Astrological Association GB) and Athan J. Zervas (astrologer and Critique Partner/Associate for Art & Design for the magazine). All of IAM issues are non-thematic and in every issue there is a cryptic phrase on the cover that refers to either the essence of the skies for the two months ahead or to a main article. -
Taxnotes® Volume 152, Number 3 July 18, 2016 C a Nlss21.Alrgt Eevd a Nlssde O Li Oyih Naypbi Oano Hr at Content
taxnotes® Volume 152, Number 3 July 18, 2016 (C) Tax Analysts 2016. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content. Debt-Equity Controversy Echoes Entity Classification Debate By David F. Levy, Nickolas P. Gianou, and Kevin M. Jones Reprinted from Tax Notes, July 18, 2016, p. 363 SPECIAL REPORT (C) Tax Analysts 2016. All rights reserved. does not claim copyright in any public domain or third party content. tax notes™ Debt-Equity Controversy Echoes Although folks far more talented and influential than the three of us will undoubtedly write on Entity Classification Debate weighty topics such as the regulations’ validity, by David F. Levy, Nickolas P. Gianou, and their arbitrary nature, and so on, we thought it Kevin M. Jones might be interesting to explore one aspect of the proposed regulations not yet discussed: the para- llels between Treasury’s current approach on debt- equity classification and its initial approach (beginning in the 1920s) on entity classification. Although the questions may at first blush seem completely unrelated, whether a particular corpo- rate financial instrument is classified for tax pur- poses as debt or equity and whether a particular business entity is classified for tax purposes as a corporation or a passthrough are, from the perspec- David F. Levy Nickolas P. Gianou Kevin M. Jones tive of corporate tax policy, two sides of the same David F. Levy is a partner, and Nickolas P. coin. And given that Treasury’s initial pre-check- Gianou and Kevin M. Jones are tax associates, with the-box approach to entity classification proved to Skadden, Arps, Slate, Meagher & Flom LLP.