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Making The Most Of Mentoring Relationships, Nicole Branch, K. Downing 2016 Santa Clara University

Making The Most Of Mentoring Relationships, Nicole Branch, K. Downing

Nicole Branch

No abstract provided.


Burgers, Doughnuts, And Expatriations: An Analysis Of The Tax Inversion Epidemic And A Solution Presented Through The Lens Of The Burger King-Tim Hortons Merger, Chris Capurso 2016 College of William & Mary Law School

Burgers, Doughnuts, And Expatriations: An Analysis Of The Tax Inversion Epidemic And A Solution Presented Through The Lens Of The Burger King-Tim Hortons Merger, Chris Capurso

William & Mary Business Law Review

Currently, the concept of tax inversion is a major corporate phenomenon. In the United States, companies pay taxes on all earnings, whether or not they were accumulated here. With one of the highest corporate tax rates in the world, this is a major expense for U.S. corporations competing in the world market. While most companies simply deal with the tax burden, some U.S. corporations buy foreign companies and relocate the company headquarters to the acquisition’s home country. This corporate expatriation allows companies to avoid U.S. taxes on earnings in a number of ways. This Note will ...


Round-Tripping Of Domestic Profits Under The American Jobs Creation Act Of 2004, Sebastien Bradley 2016 Drexel University

Round-Tripping Of Domestic Profits Under The American Jobs Creation Act Of 2004, Sebastien Bradley

Sebastien J Bradley

The American Jobs Creation Act of 2004 provided a substantial tax benefit to U.S. multinational corporations in the form of a temporary 85 percent deduction for repatriated dividends. An unforeseen consequence of this tax holiday may have also been to induce firms to reallocate earnings toward low-tax foreign subsidiaries for immediate repatriation and thereby escape higher rates of corporate income taxation. I estimate this unconventional form of round-tripping to have increased reported earnings among repatriating affiliates by $17 billion, suggesting moderate aggregate effects of a large temporary reduction in the repatriation tax on short-run income reallocation activity. Results involving ...


Public Finance And Tax Equity In The Arabian Gulf Monarchies, Timothy Mathews 2016 Kennesaw State University

Public Finance And Tax Equity In The Arabian Gulf Monarchies, Timothy Mathews

Journal of Global Initiatives: Policy, Pedagogy, Perspective

This study examines notions of public finance equity in the six Arabian Gulf monarchies of Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates. Because of unique characteristics of government expenditures and revenues in these monarchies, many of the standard concepts of public finance (such as the Benefits Principle, Ability-to-Pay Principle, Vertical Equity, and Horizontal Equity) do not provide relevant insights. Consequently, four innovative notions of equity are reviewed and discussed: Within Group Horizontal Equity; Within Group Vertical Equity; Favored Group Horizontal Equity; and Favored Group Vertical Equity. Finally, these four conceptions of equity are applied to a ...


The Benefits Of Having A Comprehensive Financial Plan For The Average Consumer, And The Necessary Components Comprised To Make An Effective And Efficient Plan, Nicholas M. Lund 2016 Claremont McKenna College

The Benefits Of Having A Comprehensive Financial Plan For The Average Consumer, And The Necessary Components Comprised To Make An Effective And Efficient Plan, Nicholas M. Lund

CMC Senior Theses

Socioeconomic changes in American society over the past few decades, as well as an overwhelming amount of uncertainty and misconceptions, have resulted in a majority of Americans to fall short of their financial goals in the short-term, the mid-term, and the long-term. Without proper preparation and financial planning, it is likely that these Americans, and many more, will be unable to reach these goals as well as retire comfortably. Many Americans are overwhelmed with the immense amount of financial information, tools and resources, and as a consequence are unable to plan their finances efficiently and effectively. Americans need a better ...


Problematic Self-Directed Retirement Plan Activities, David Jenkins 2015 Unaffiliated

Problematic Self-Directed Retirement Plan Activities, David Jenkins

David Randall Jenkins

My paper “Section 4975(e)(2)(G) Management and Investment Risk Diversification Standards” teaches the retirement plan (self-dealing activity, incidental benefit) bright line is quantified and defined by public policy’s management and investment risk diversification standards. Such retirement plan risk diversification policy compliance results in transforming generally proscribed Sections 4975(c)(1)(D), (E), or (F) prohibited transaction self-dealing activities into incidental benefits. My paper “Prohibited Transaction Chinese Walls” teaches eviscerating the self-dealing activity nexus plan asset element by and through properly invoking plan asset rule exceptions enables transforming specifically proscribed Sections 4975(c)(1)(A), (B), or (C ...


Investor Valuations Of Japan's Adoption Of A Territorial Tax Regime: Quantifying The Direct And Competitive Effects Of International Tax Reform, Sebastien Bradley, Estelle Dauchy, Makoto Hasegawa 2015 Drexel University

Investor Valuations Of Japan's Adoption Of A Territorial Tax Regime: Quantifying The Direct And Competitive Effects Of International Tax Reform, Sebastien Bradley, Estelle Dauchy, Makoto Hasegawa

Sebastien J Bradley

Despite an extensive literature on the normative implications of different international tax regimes and an empirical literature addressing individual specific predictions, there exists little evidence encompassing the broad range of effects of taxing corporations' foreign-source income on a worldwide or territorial basis. This paper takes a more comprehensive quantitative approach by examining stock market reactions surrounding four events over the course of which Japan's 2009 adoption of a dividend exemption system was developed into proposed law. Using an event study methodology which leverages individual firm characteristics and accounts for contemporaneous financial market developments, we find that Japanese firms with ...


Foreign Account Tax Compliance Act: The Most Revolutionary Piece Of Tax Legislation Since The Introduction Of The Income Tax, Alexander Szwakob 2015 University of Connecticut

Foreign Account Tax Compliance Act: The Most Revolutionary Piece Of Tax Legislation Since The Introduction Of The Income Tax, Alexander Szwakob

Honors Scholar Theses

With taxation of income being the most significant source of revenue, most national governments consider tax evasion prevention to be one of the priorities of their tax agencies. In the United States, tax evasion has been a significant concern of the Internal Revenue Service ever since the modern income tax was instituted with the passing of the Sixteenth Amendment in 1913. Over the following century, Congress enacted numerous measures aimed at curbing the illegal practice, but, as often is the case, both individuals and institutions desiring to not abide by the law found new ways to outsmart the tax authorities ...


The Tax Treatment Of Fringe Benefits, Stephen Woodbury, Wei-Jang Huang 2015 Michigan State University and W.E. Upjohn Institute

The Tax Treatment Of Fringe Benefits, Stephen Woodbury, Wei-Jang Huang

Stephen A. Woodbury

Woodbury and Huang use econometric models to investigate how changes in the tax treatment of fringe benefits can be expected to influence the level of benefits and compensation provided by employers, federal revenues, and income inequality.


Knowledge Of Federal Taxation In The Millennial Age, Jordan Kulow 2015 Iowa State University

Knowledge Of Federal Taxation In The Millennial Age, Jordan Kulow

Honors Projects and Posters

The goal of this study is to build upon previous research, studying the knowledge of taxation in elementary children, by researching the same idea in college-aged students. To do so, students were surveyed regarding various demographics and taxation topics in terms of general knowledge, taxation concepts that are currently relevant to our target subject, and taxation topics that will be relevant to them in the future. Our results showed that students had a moderate level of general knowledge that was consistent across variables. They also showed that in terms of taxation topics that are currently relevant, being older and having ...


Cross-Country Evidence On The Preliminary Effects Of Patent Box Regimes On Patent Activity And Ownership, Sebastien Bradley, Estelle Dauchy, Leslie Robinson 2015 Drexel University

Cross-Country Evidence On The Preliminary Effects Of Patent Box Regimes On Patent Activity And Ownership, Sebastien Bradley, Estelle Dauchy, Leslie Robinson

Sebastien J Bradley

This paper evaluates the initial impacts of patent box regimes in light of their primary stated objectives: stimulating domestic innovation and retaining mobile patent income to limit base erosion. Despite their lack of nexus requirements, we find that patent box regimes yield a 3 percent increase in new patent applications for every percentage point reduction in the tax rate on patent income. We find no significant impact of these regimes on deterring outward cross-border attribution of patent ownership, or on attracting ownership of foreign inventions. Increased patenting activity hence appears focused on inventions involving co-located (domestic) patent owners and inventors.


The Common Knowledge Of Tax Abuse, Mark Gergen 2015 Berkeley Law

The Common Knowledge Of Tax Abuse, Mark Gergen

Mark P. Gergen

No abstract provided.


The Influence Of Tax Law On Securities Innovation In The United States: 1981-1997, Mark Gergen, Paula Schmitz 2015 Berkeley Law

The Influence Of Tax Law On Securities Innovation In The United States: 1981-1997, Mark Gergen, Paula Schmitz

Mark P. Gergen

No abstract provided.


Hardship Withdrawals And Loans: Some Words Of Caution, Emily Brown, Jeanne Medeiros, Ellen Bruce 2015 University of Massachusetts Boston

Hardship Withdrawals And Loans: Some Words Of Caution, Emily Brown, Jeanne Medeiros, Ellen Bruce

Ellen Bruce

As defined benefit pension plans become more and more rare, the responsibility of saving for retirement falls increasingly on individuals. Many studies have been published about the average or median balances in retirement savings accounts and virtually all of them have reached the same conclusion - most Americans aren’t saving enough money to last them through their retirement years.

In this fact sheet we will take a look at one of the factors that contributes to this problem, that is, the availability of loans and hardship withdrawals from 401(k) retirement accounts, which can lead to lower account balances overall ...


Assessment Limits And Timing Of Real Estate Transactions, Sebastien Bradley 2015 Drexel University

Assessment Limits And Timing Of Real Estate Transactions, Sebastien Bradley

Sebastien J Bradley

Michigan homebuyers face large potential discontinuities in tax obligations for purchases made around January 1 and May 1 under the state's application of acquisition-value based assessment limits and principal residence (homestead) exemptions, respectively. Consistent with incentives, roughly 3.7 percent of sales concluded in the first 10 business days of January are thus attributable to timing responses among the subset of properties listed by the largest 25 percent of firms by sales volume. Underlying this effect is a willingness to stretch the number of days between contract and closing dates by an average of 2 to 4 business days ...


Simple Substantial Economic Effect Regulatory Compliance, David Jenkins 2015 Unaffiliated

Simple Substantial Economic Effect Regulatory Compliance, David Jenkins

David Randall Jenkins

The Internal Revenue Service considers Section 704(b)’s substantial economic effect regulations among the most complex. This course teaches the Treasury Regulations enable simple compliance through (Per Capita: Balances: Ratios) capital account accounting method truncated transitivity, economic effect equivalence, and substantiality’s conclusive presumption. The partnership special allocations public policy mandate is made clear thereby: encourage going concern productivity while discouraging its abandonment.


Evaluating Policy Measures To Tackle Undeclared Work: The Role Of Stakeholder Collaboration In Building Trust And Improving Policy-Making, Colin Williams, Anton Kojouharov 2015 University of Sheffield

Evaluating Policy Measures To Tackle Undeclared Work: The Role Of Stakeholder Collaboration In Building Trust And Improving Policy-Making, Colin Williams, Anton Kojouharov

Colin C Williams

The aim of this paper is to examine and analyse the realm of policy evaluation approaches and methods as they relate to assessing measures to tackle undeclared work. The discussion is set at the backdrop of a brief review of the more prominent theoretical and conceptual considerations in the policy evaluation literature. The paper then investigates results from policy assessments and evaluations illuminated in the previous GREY working papers, as well as some selected from the Eurofound database. The analysis of a limited sample of available policy evaluations and results demonstrates that a common probable cause of policy failure with ...


Pass-Through Valuation, Robert M. Hull, David P. Price 2015 Washburn University

Pass-Through Valuation, Robert M. Hull, David P. Price

The Journal of Entrepreneurial Finance

Noted scholars argue that (1) economic models of capital taxation have been inadequately adapted to owner-managed enterprises and (2) capital structure researchers have used the wrong models while also improperly measuring key variables. Thus, a model that can overcome these problems should be of interest to academics when teaching capital structure theory and practitioners when determining optimal debt levels. This paper contributes to capital structure practice by using a model that is adaptable to owner-managed enterprises like pass-throughs while also containing relevant variables that are measurable. This paper should be valuable to academics and practitioners in the following ways. First ...


Se(C)(3): A Catalyst For Social Enterprise Crowdfunding, Dana Brakman Reiser, Steven A. Dean 2015 Brooklyn Law School

Se(C)(3): A Catalyst For Social Enterprise Crowdfunding, Dana Brakman Reiser, Steven A. Dean

Indiana Law Journal

The emerging consensus among scholars rejects the notion of tax breaks for social enterprises, concluding that such prizes will attract strategic claimants, ultimately doing more harm than good. The SE(c)(3) regime proposed by this Article offers entrepreneurs and investors committed to combining financial returns and social good with a means of broadcasting that shared resolve. Combining a measured tax benefit for mission-driven activities with a heightened burden on shareholder financial gains, the revenue-neutral SE(c)(3) regime would provide investors and funding platforms with a low-cost means of screening out “greenwashed” ventures.


Designing Survey Methods To Evaluate The Undeclared Economy: A Review Of The Options, Colin Williams 2015 University of Sheffield

Designing Survey Methods To Evaluate The Undeclared Economy: A Review Of The Options, Colin Williams

Colin C Williams

This Working Paper is part of the GREY project which is developing capacities and capabilities in tackling undeclared work. In this Working Paper, the various options available to researchers when designing surveys to tackle undeclared work are evaluated. These issues include the unit of analysis used, the data collection methodology, an array of questionnaire design issues (including the reference period, whether to define the phenomenon for participants, a direct versus gradual approach to sensitive issues, whether to do a supply- and/or demand-side survey; whether to examine the relationship between purchasers and sellers, how to discourage social desirability bias), sample ...


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