SUMMER 2021 Tax Compliance Software Category
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Taxation Paradigms: JOHN WEBB SUBMISSION APRIL 2009
Taxation Paradigms: What is the East Anglian Perception? JOHN WEBB A thesis submitted in partial fulfilment of the requirements of Bournemouth University for the degree of Doctor of Philosophy SUBMISSION APRIL 2009 BOURNEMOUTH UNIVERSITY What we calf t[ie beginningis oftenthe end And to makean endis to makea beginning ?fie endis wherewe start ++++++++++++++++++ Weshall not ceasefrom exploration And the of exploring end .. Wilt to arrivewhere we started +++++++++++++++++ 7.S f: Cwt(1974,208: 209) ? fie Four Quartets,Coffected Poems, 1909-1962 London: Faderand Fader 2 Acknowledgements The path of a part time PhD is long and at times painful and is only achievablewith the continued support of family, friends and colleagues. There is only one place to start and that is my immediate family; my wife, Libby, and daughter Amy, have shown incredible patienceover the last few years and deserve my earnest thanks and admiration for their fantastic support. It is far too easy to defer researchwhilst there is pressingand important targets to be met at work. My Dean of Faculty and Head of Department have shown consistent support and, in particular over the last year my workload has been managedto allow completion. Particularthanks are reservedfor the most patientand supportiveperson - my supervisor ProfessorPhilip Hardwick.I am sure I am one of many researcherswho would not have completed without Philip - thank you. ABSTRACT Ever since the Peasant'sRevolt in 1379, collection of our taxes has been unpopular. In particular when the taxes are viewed as unfair the population have reacted in significant and even violent ways. For example the Hearth Tax of 1662, Window Tax of 1747 and the Poll tax of the 1990's have experiencedpublic rejection of these levies. -
Tax Heavens: Methods and Tactics for Corporate Profit Shifting
Tax Heavens: Methods and Tactics for Corporate Profit Shifting By Mark Holtzblatt, Eva K. Jermakowicz and Barry J. Epstein MARK HOLTZBLATT, Ph.D., CPA, is an Associate Professor of Accounting at Cleveland State University in the Monte Ahuja College of Business, teaching In- ternational Accounting and Taxation at the graduate and undergraduate levels. axes paid to governments are among the most significant costs incurred by businesses and individuals. Tax planning evaluates various tax strategies in Torder to determine how to conduct business (and personal transactions) in ways that will reduce or eliminate taxes paid to various governments, with the objective, in the case of multinational corporations, of minimizing the aggregate of taxes paid worldwide. Well-managed entities appropriately attempt to minimize the taxes they pay while making sure they are in full compliance with applicable tax laws. This process—the legitimate lessening of income tax expense—is often EVA K. JERMAKOWICZ, Ph.D., CPA, is a referred to as tax avoidance, thus distinguishing it from tax evasion, which is illegal. Professor of Accounting and Chair of the Although to some listeners’ ears the term tax avoidance may sound pejorative, Accounting Department at Tennessee the practice is fully consistent with the valid, even paramount, goal of financial State University. management, which is to maximize returns to businesses’ ownership interests. Indeed, to do otherwise would represent nonfeasance in office by corporate managers and board members. Multinational corporations make several important decisions in which taxation is a very important factor, such as where to locate a foreign operation, what legal form the operations should assume and how the operations are to be financed. -
US-Steuerreform: Chancen Und Risiken: Wer Gewinnt – Wer Verliert?
ZUR DISKUSSION GESTELLT US-Steuerreform: Chancen und Risiken: Wer gewinnt – wer verliert? Die Steuerreform von US-Präsident Donald Trump sieht deutliche Steuersenkungen für Unternehmen und bescheidene Entlastungen für Privatpersonen vor. Vor allem Bezieher hoher Einkommen werden von der Reform profitieren. Zudem dürften die Staatsschulden nach vorläufigen Berechnungen über das kommende Jahrzehnt um mindestens eine Bil- lion Dollar anwachsen. Die Steuerreform wird aber auch voraussichtlich die Konjunktur in den USA anschieben, und sie wird den USA durch die Senkung der Unternehmensteuer- sätze einen massiven Wettbewerbsvorteil bescheren. Wie sollten die europäischen Länder reagieren? wirkungen auf effektive Unternehmensteuerbelas- Christoph Spengel*, Marcel Olbert** und tungen und die damit verbundenen Konsequen- Kathrin Stutzenberger*** zen, mögliche Folgen für die Entwicklung ausländi- scher Direktinvestitionen sowie auf das Verhältnis US-Steuerreform 2018 – der Reform zu aktuellen steuerpolitischen Entwick- Implikationen und lungen auf EU-Ebene eingegangen (vgl. Spengel et al. 2018). Konsequenzen für Europa1 AUSWIRKUNGEN DER US-STEUERREFORM AUF DIE Christoph Spengel Am 22. Dezember 2017 verabschiedete US-Präsident EFFEKTIVE UNTERNEHMENSTEUERBELASTUNG Donald Trump mit Unterzeichnung des »Tax Cuts and Jobs Act« die größte Reform des US-Steuersystems seit Die Konsequenzen der USSteuerreform für die effek- 1986. Diese sieht mit Wirkung ab dem 1. Januar 2018 auf tive Unternehmensteuerbelastung im Verhältnis zu Unternehmensebene neben einer -
The Relationship Between MNE Tax Haven Use and FDI Into Developing Economies Characterized by Capital Flight
1 The relationship between MNE tax haven use and FDI into developing economies characterized by capital flight By Ali Ahmed, Chris Jones and Yama Temouri* The use of tax havens by multinationals is a pervasive activity in international business. However, we know little about the complementary relationship between tax haven use and foreign direct investment (FDI) in the developing world. Drawing on internalization theory, we develop a conceptual framework that explores this relationship and allows us to contribute to the literature on the determinants of tax haven use by developed-country multinationals. Using a large, firm-level data set, we test the model and find a strong positive association between tax haven use and FDI into countries characterized by low economic development and extreme levels of capital flight. This paper contributes to the literature by adding an important dimension to our understanding of the motives for which MNEs invest in tax havens and has important policy implications at both the domestic and the international level. Keywords: capital flight, economic development, institutions, tax havens, wealth extraction 1. Introduction Multinational enterprises (MNEs) from the developed world own different types of subsidiaries in increasingly complex networks across the globe. Some of the foreign host locations are characterized by light-touch regulation and secrecy, as well as low tax rates on financial capital. These so-called tax havens have received widespread media attention in recent years. In this paper, we explore the relationship between tax haven use and foreign direct investment (FDI) in developing countries, which are often characterized by weak institutions, market imperfections and a propensity for significant capital flight. -
September 15, 2020 What's in and What's out of the Final 2020 Tax
September 15, 2020 What’s In and What’s Out of the Final 2020 Tax Package The 2020 tax package (HB 7097) was amended many times as it moved through the process. At first it grew, topping $230 million in tax savings at one point. Then, citing a need to keep more money in reserves for COVID-19 response, it started getting smaller. The total of the final tax package is $47.4 million, $10.8 million of which is local. All of the savings comes from two sales tax holidays, so the tax cuts are one-time. This reduces the tax package's fiscal hit to the state to $36.6 million in the upcoming budget year, with no recurring impact. The original tax package, developed in the House Ways and Means Committee, contained a mix of tax cuts and tax The Evolving Tax Package administration changes. Most of the cuts were small. The Version Tax Savings two largest tax cuts in the bill were both Florida TaxWatch House Ways & Means $167.2 priorities--a reduction in the communication services tax House Appropriations $193.4 (CST) of 0.5 percent and a reduction in the business rent tax Passed by House $198.4 (BRT) from 5.5 percent to 5.4 percent. The original bill Senate Appropriations $233.7 Senate 2nd Reading $107.1 would have reduced state and local taxes by $162.7 million Final Bill $47.4 (the sum of the one-time cuts and the recurring cuts1). More cuts were added in House the Appropriations Committee, pushing the total to $193.4 million. -
International Cooperation and the 2017 Tax Act Susan C
THE YALE LAW JOURNAL FORUM O CTOBER 25, 2018 International Cooperation and the 2017 Tax Act Susan C. Morse abstract. There is a silver lining for the corporate income tax in the Tax Cuts and Jobs Act of 2017. This is because the Act’s international provisions contain not only competitive but also cooperative elements. The Act adopts a lower, dual-rate structure that pursues a competitiveness strategy and taxes regular corporate income at 21% and foreign-derived intangible income at 13.125%. But the Act also supports the continued existence of the corporate income tax globally, thus favoring cooperation among members of the Organisation for Economic Cooperation and Development (OECD). Its cooperative provisions feature the minimum tax on global intangible low-taxed income, or GILTI, earned by non-U.S. subsidiaries. Another cooperative provision is the base erosion and anti-abuse tax, or BEAT. The impact of the Act on global corporate income tax policy will depend on how the U.S. implements the law and on how other nations respond to it. introduction In 2017, House Speaker Paul Ryan, Representative Kevin Brady, and Senator Mitch McConnell accomplished something that many others, including former President Barack Obama, had long aimed to achieve. They lowered the federal corporate tax rate so that the U.S. rate now falls within the same range of rates used in most of the rest of the world. The Tax Cuts and Jobs Act of 2017 (TCJA) has attracted just criticism for its deficit financing, for its abysmal legislative craftsmanship, and for its sometimes-misguided policy objectives.1 But Con- gress deserves credit for the TCJA’s international corporate tax provisions that 1. -
Curacao Highlights 2020
International Tax Curaçao Highlights 2020 Updated January 2020 Recent developments: For the latest tax developments relating to Curaçao, see Deloitte tax@hand. Investment basics: Currency – Netherlands Antilles Guilder (ANG) Foreign exchange control – A 1% license fee will be calculated as a percentage of the gross outflow of money on transfers from residents to nonresidents, and on foreign currency cash transactions. Holding companies may obtain an exemption from the fee. Accounting principles/financial statements – IAS/IFRS applies. Financial statements must be prepared annually. Principal business entities – These are the public and private company (NV and BV), general partnership, (private) foundation, Curaçao trust, limited partnership, and branch of a foreign corporation. Corporate taxation: Rates Corporate income tax rate 22%/3%/0% Branch tax rate 22%/3%/0% Capital gains tax rate 22%/3%/0% Residence – A corporation is resident if it is incorporated under the laws of Curaçao or managed and controlled in Curaçao. Basis – In principle, residents are taxed on worldwide income. Exemptions may apply for profits derived by permanent establishments located abroad. In addition, as from 1 July 2018, foreign-source income is excluded from the profit tax base (although there is an exception for certain services, including insurance and reinsurance activities; trust activities; the services of notaries, lawyers, public accountants and tax consultants; related services; income derived from the exploitation of intellectual property (IP); and shipping activities). Page 1 of 7 Curaçao Highlights 2020 Nonresidents are taxed only on Curaçao-source income. Foreign-source income derived by residents that is not excluded from the profit tax base is subject to corporation tax in the same way as Curaçao-source income. -
Is Paying Taxes Habit Forming? Evidence from Uruguay
Is Paying Taxes Habit Forming? Evidence from Uruguay Thad Dunning,∗ Felipe Monestiery Rafael Pineiro,˜ z Fernando Rosenblatt,x and Guadalupe Tun˜on´ { This draft: October 16, 2016 Prepared for presentation at the Comparative Politics Colloquium, University of California, Berkeley, October 20, 2016. We are grateful to Lihuen Nocetto for research assistance and to the J-PAL Governance Initiative for generous funding. We received helpful comments on this project from participants at EGAP meetings at Columbia University and the Universidad Diego Portales (Chile), the Political Geography Conference at Harvard, and seminars at Emory, Indiana University Bloomington, McGill, Princeton, Stanford, UCLA, University of Pennsylvania, University of Wisconsin-Madison, and Yale. The pre-analysis plan for this project was registered with EGAP (www.e-gap.org/design-registrations) as well as the American Economic Association (www.socialscienceregistry.org) in July 2014. The study was approved by the Office for the Protection of Human Subjects at the University of California, Berkeley (Protocol ID 2014-04-6286). ∗University of California, Berkeley. yUniversidad de la Republica,´ Montevideo, Uruguay zUniversidad Catolica,´ Montevideo, Uruguay xUniversidad Diego Portales, Santiago, Chile {University of California, Berkeley and University of Pennsylvania. 1 Abstract Interactions between citizens and their states often involve routinized, repeated behaviors—and repetition may itself breed habits of citizenship that exert a causal influence on behavior. This implies the possibility of virtuous or vicious cycles in civic participation, as well as broader development outcomes. Yet, it is usually difficult to separate habit from confounding explanations for repeated behaviors. We study a policy in Montevideo, Uruguay that randomly assigns tax holidays, or year-long interruptions of payments, to punctual taxpayers; the program is designed both to reward and induce tax compliance, a critical aspect of citizen-state interaction and a key facet of state capacity. -
Keys to Understanding and Utilizing the Federal and California Research Tax Credits
UPDATE ON E-COMMERCE TAXATION: FOCUS ON EVENTS OF THE PAST YEAR April 2001 Annette Nellen, CPA, Esq. Graduate Tax Program San José State University http://www.cob.sjsu.edu/facstaff/nellen_a/ WEB SITE FOR ADDITIONAL INFORMATION ON E-COMMERCE TAXATION + LINKS http://www.cob.sjsu.edu/facstaff/nellen_a/e-links.html WHY TAX ISSUES EXIST “E-commerce represents a new business model. As such, it creates some challenges to tax systems that were designed with a different model in mind. Two key reasons help explain why e-commerce raises tax issues: 1. Location—Existing tax systems tend to determine tax consequences based on where the taxpayer is physically located. The e-commerce model enables businesses to operate with very few physical locations. 2. Nature of products—E-commerce allows for some types of products, such as newspapers and music CDs, to be delivered in digitized (intangible) form, rather than in tangible form. Digitized products may not be subject to sales tax in some states. Also, the ability to deliver digitized products, as well as services over the Internet also reduces the need for physical locations, thus creating fewer taxing points.”1 See Appendix A for additional reasons why e-commerce raises tax issues for both taxpayers and taxing authorities. THE COSTS OF E-COMMERCE TAXATION ISSUES A. State and Local Government E-commerce is in its infancy because it represents less than 1% of retail sales. Also, less than 3% of the world's population is on-line. But, the growth potential is great. The Department of Commerce projects that e-commerce will grow to hundreds of billions of dollars annually. -
Tech Untaxed: Tax Avoidance in Silicon Valley, and How America's Richest Company Pays a Lower Tax Rate Than You Do
2012 Tech Untaxed: Tax Avoidance in Silicon Valley, and How America’s Richest Company Pays a Lower Tax Rate than You Do SAMUEL S. KANG and TUAN NGO I The Greenlining Institute Tech Untaxed: Tax Avoidance in Silicon Valley, and How America’s Richest Company Pays a Lower Tax Rate than You Do SAMUEL S. KANG and TUAN NGO I The Greenlining Institute APRIL 2012 About the Greenlining Institute The Greenlining Institute is a national policy, research, organizing, and leadership institute working for racial and economic justice. We ensure that grassroots leaders are participating in major policy debates by building diverse coalitions that work together to advance solutions to our nation’s most pressing problems. Greenlining builds public awareness of issues facing communities of color, increases civic participation, and advocates for public and private policies that create opportunities for people and families to make the American Dream a reality. About Greenlining’s Consumer Protection Program and Our Legal Team Led by General Counsel Samuel Kang, Greenlining uses inhouse legal experts to ensure that there is equity in the state’s energy, telecom, and cable industries. Greenlining’s legal team is one of the few active racial justice advocates at the California Public Utilities Commission, the Federal Communications Commission, and other regulatory bodies. They work closely with grassroots leaders to ensure that the needs and solutions of communities of color are represented in the halls of these commissions. Greenlining plays a critical role in ensuring that California’s regulated companies remain leaders on issues of diversity and economic equity. In addition, our legal team builds bridges between grassroots leaders and corporate CEOs to ensure that positive dialogue leads to winwin solutions. -
Office of CFO Market Map: Tax Management Software January 2021 Agenda
Office of CFO Market Map: Tax Management Software January 2021 Agenda Shea & Company Overview Office of the CFO Market Overview Market Activity 1 Shea & Company Overview About Our Firm 1 2 29 $10Bn+ 15+ 100+ Firm focused exclusively on Offices in Boston and San Professionals focused on the Advised transaction value in Average years of experience Transactions completed enterprise software Francisco software industry last 12 months amongst our senior bankers representing billions of dollars in value Mergers & Acquisitions, Private Placements & Capital Raising Shea & Company has advised on important transactions representing billions of dollars in value across the strategic acquirer and financial investor landscape with Clients in the U.S. as well as Canada, Europe and Israel. has received a majority investment has received an investment from has been acquired by has received an investment from has made a majority investment in has received an investment from has acquired from Public Sector & Healthcare has been acquired by has received an investment from has been acquired by has been acquired by have been merged with has acquired has acquired has acquired has been acquired by has received an investment from has received an investment from has been acquired by has received an investment from has been acquired by 2 Shea & Company Overview Case Study: HgCapital’s Acquisition of Sovos Compliance Transaction Profile Sovos Profile HGCapital Profile In March 2016, HgCapital announced a majority investment in Sovos is a leading provider of regulatory -
Countries' Effective and Efficient Use of Tax Incentives for Investment
Options for Low Income Countries' Effective and Efficient Use of Tax Incentives for Investment A REPORT TO THE G-20 DEVELOPMENT WORKING GROUP BY THE IMF, OECD, UN AND WORLD BANK Options for Low Income Countries’ Effective and Efficient Use of Tax Incentives for Investment A REPORT TO THE G-20 DEVELOPMENT WORKING GROUP BY THE IMF, OECD, UN AND WORLD BANK This report was prepared at the request of the G20 Development Working Group by the staffs of the International Monetary Fund, the Organisation for Economic Co-operation and Development, the United Nations and the World Bank. I t h a s benefitted from consultation with other organisations working in the tax area, officials of developing countries, Civil Society Organisations, and business representatives. The report is prepared under the responsibility of the Secretariats and Staff of the four organisations. It reflects a broad consensus among these staff, but should not necessarily be regarded as the officially-endorsed views of those organisations or their member states. The report was presented as requested to the G20 DWG in September, 2015, and to the Executive Board of the IMF for information, in October, 2015. OPTIONS FOR LOW INCOME COUNTRIES' EFFECTIVE AND October 15, 2015 EFFICIENT USE OF TAX INCENTIVES FOR INVESTMENT EXECUTIVE SUMMARY Experience shows that there is often ample room for more effective and efficient use of investment tax incentives in low-income countries. Tax incentives generally rank low in investment climate surveys in low-income countries, and there are many examples in which they are reported to be redundant—that is, investment would have been undertaken even without them.