Ownership neutrality, ownership distortions, and international
tax welfare benchmarks.
The literature analyzing the efficiency consequences of
international tax policy has for many years emphasized the impact of a
nation's tax laws on the location of capital (either in saving or
in . . .
Lipstick, light beer, and back-loaded savings accounts.
"We'd like to see as many advertisements for lifetime savings accounts
as we do for lipstick and light beer." (1)
I. INTRODUCTION
In recent years the Bush Administration has repeatedly . . .
The Digital VAT (D-VAT). (value added tax)
I. INTRODUCTION
The most sustained U.S. tax policy debate of the past thirty years
concerns proposals to replace and/or supplement the federal income tax
with a consumption tax. (1) Public . . .
Tax advice before the return: the case for raising standards and
denying evidentiary privileges.
Abusive tax shelters have shone an unappealing light on tax
lawyers. Some commentators suggest that these abusive shelters are the
work of a small tax shelter bar. This article argues that the . . .
An interview with Mortimer Caplin.(Interview)
The following interview was originally published in TAXES--The Tax
Magazine on October 1, 2004.
Mortimer Caplin is the founding member of Caplin & Drysdale,
Chartered, Washington, D.C.
Mortimer . . .
Prevention of double deductions of a single loss: solutions in
search of a problem.
I. INTRODUCTION
In the current tax system, a corporation is treated as a separate
taxable entity. (1) This tax system is sometimes referred to as an
entity tax or a double tax system. (2) Since a . . .
Towards equity and efficiency in partnership allocations.
I. INTRODUCTION
The primary goal of any tax system is to raise sufficient revenue
for government. (1) More precisely, taxation is the means by which
government supplies necessary things not . . .
The "bidding war" to attract foreign direct investment:
the need for a global solution.
It is a widely accepted practice by governments to grant tax
incentives to entice and retain foreign direct investment (FDI). Since
many countries seek to attract FDI, an "incentive competition"
or . . .
Celebrating Edwin S. Cohen - "master
practitioner-teacher" September 27, 1914-January 12,
2006.(Testimonial)
Ed Cohen and I enrolled at the University at the same time,
1933--he at the School of Law (hardly 19); I at the College of Arts
& Sciences. Ed would have said: "We went to . . .
Vigilante nonprofits: the Bob Jones rule as applied to the
international promotion of the rule of law.
I. INTRODUCTION
Imagine a small European nation in which physician-assisted suicide
for the terminally ill has been legalized. Perhaps organizations aiding
in the provision of such services have . . .
Taxing the global worker: three spheres of international social
security coordination.
Social security is a fundamental part of workers' lives in
three spheres: contributions are required, benefits are hoped for, and
taxes on benefits may have to be paid. If a worker splits a . . .
The case against income averaging.
Should tax liability be based on annual income or on the average of
a taxpayer's income earned over the space of several years (or even
a lifetime)? This article assesses proposals to replace the . . .
A lifetime income tax.
Under current tax law, there can be considerable period-by-period
divergence between a taxpayer's after-tax income and her desired or
actual consumption. This divergence will cause the taxpayer to . . .
An evaluation of federal tax policy based on Judeo-Christian
ethics.
"So be careful to do what the Lord your God has commanded you; do not
turn aside to the right or to the left. Walk in all the way that the
Lord your God has commanded you, so that you may live and . . .
The tax lawyer's role in the way the American tax system
works.(13th Annual Erwin N. Griswold Lecture Before the American Colleg
13TH ANNUAL ERWIN N. GRISWOLD LECTURE BEFORE
THE AMERICAN COLLEGE OF TAX COUNSEL
SAN DIEGO, CALIFORNIA, JANUARY 22, 2005
It is a high privilege to be asked to deliver this Erwin N.
Griswold . . .
Reforming the branch profits tax to advance neutrality.
I. INTRODUCTION
In several respects, the U.S. tax system strives for neutral
taxation. Neutrality is often concerned with similarly taxing different
types of income that are economically . . .
Assessing Internal Revenue Code section 132 after twenty
years.
In 1984, Congress enacted Internal Revenue Code section 132 to
bring more certainty to the taxation of employee fringe benefits. This
article examines the impact of the legislation from the . . .
The taxation of income available for discretionary use.
While the signature tax policy tension of the last two decades (at
least) has been whether the federal tax base ought to reach
"income" or only "consumption," there is, I believe,
a persuasive . . .
Edwin S. Cohen.(Testimonial)
This is not the first time I have spoken to honor Edwin S. Cohen. I
spoke at two of his retirements--at least--and in the Rotunda at both
his 75th and 90th birthday celebrations. Each time, and on . . .
The perils of bright lines: section 6110(K)(3) and the ambiguous
precedential status of written determinations.
I. INTRODUCTION
Internal Revenue Code (Code) section 6110(k)(3) states that, with
certain minor exceptions, "a written determination may not be used
or cited as precedent." (1) Overlooked in . . .
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