Taxation Commons^™

Post-Jgtrra Dividend Planning, Danny A. Pannese, Paul N. Iannone

Danny Pannese

The JGTRRA reduced the tax rate on dividends for individuals and lowered the accumulated earnings and personal holding company taxes for corporations until 2008. This article reviews some of the planning techniques corporations and shareholders can use to take advantage of the temporarily lower rates. One of the key provisions of the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA), if not the prime emphasis of the legislation, is Section 302's reduction in the individual tax rate on corporate dividends received to 15% (5% for individuals in the 15% and 10% brackets). In an emerging trend, the ...

Liberating Trapped Cash: A Case Study Of Trapped Cash At Apple And Microsoft, Russell P. Engel, Bridget M. Lyons, Danny A. Pannese

Danny Pannese

The topic of trapped cash, or cash permanently reinvested overseas to avoid tax upon repatriation, has become a hot topic in accounting, finance and policy circles over the past two years. This case study analyzes the activities of two major technology firms, Microsoft and Apple, to liberate enormous holdings of trapped cash. The case prompts a discussion of the topic of trapped cash, stakeholder considerations and tools available to manage cash balances held outside the United States. The focus is to examine the strategies available and those selected by Microsoft and Apple to meet or at least appease stakeholder demands ...

Assessment Of Under-Declared Employment In Croatia, Colin C. Williams, Miroslav Radvansky, Miroslav Stefanik

Colin C Williams

Tackling The Participation Of Europe’S Rural Population In The Shadow Economy, Colin C. Williams, Ioana Horodnic

Colin C Williams

The Contemporary Tax Journal Volume 6, No. 2 – Spring 2017

The Contemporary Tax Journal

No abstract provided.

Country By Country Reporting Under Beps, Fenny Lei

The Contemporary Tax Journal

No abstract provided.

Summaries For The 32nd Annual Tei-Sjsu High Tech Tax Institute, Saqib Amin, Silin Chen, Ophelia Ding, Veena Hemachandran, Elle San Pedro De Kornsand, Padmini Yalamarthi, Yu Zheng

The Contemporary Tax Journal

No abstract provided.

Cpa Exam Review

The Contemporary Tax Journal

No abstract provided.

Bringing The U.S. Tax Court Exam Out Of Obscurity, Lucia Nasuti Smeal J.D., Tad D. Ransopher J.D.

The Contemporary Tax Journal

No abstract provided.

Proposition 64 Legalizes Marijuana In California But The War On Drugs Continues, Jessica Wong

The Contemporary Tax Journal

No abstract provided.

U.S. Tax Forms For American Expatriates, Saqib Amin Cpa

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal's Interview Of Mr. Gary Sprague, Xuan Hong

The Contemporary Tax Journal

No abstract provided.

Illegitimate Economic Practices In Fyr Macedonia, Colin C. Williams, Slavko Bezeredi

Colin C Williams

Democracy Ends Here: U.S. Collective Bargaining Decline And An Alternative Policy Approach To Business Ownership, Sara Estep

Senior Honors Projects

In the United States, it seems that we cannot talk about democracy without discussing capitalism and vice versa. However, as soon as we step into work these ideals are simply thrown out the door. If we seek to govern our country democratically, should we also not have a democratic governance structure in our day to day workplaces? Unions have existed in the United States for over 150 years, but as the types of jobs that make up our economy and the demographics of the labor force have changed dramatically, the basic concept of the union has remained static. In turn ...

The Impact Of Increased Tax Return Reporting On Financial Statement Tax Disclosure Quality: Evidence From Irs Schedule Utp, Michelle Kim Harding

Doctoral Dissertations

This study uses the 2010 implementation of IRS Schedule UTP (Uncertain Tax Position) to examine the impact of additional tax return reporting on financial statement tax disclosure quality. Using a hand-collected sample, I find that firms reduce the quality of their Financial Accounting Standards Board Interpretation No. 48 (FIN 48) disclosures for Accounting for Uncertainty in Income Taxes in response to increased proprietary costs of disclosure following the adoption of IRS Schedule UTP. Standard setters intended FIN 48 disclosures to benefit investors. Contrary to this intended outcome, I find that as tax return reporting increases, firms reduce discretionary FIN 48 ...

Implicit Taxes In Imperfect Markets, Hannah Elizabeth Smith

Doctoral Dissertations

Implicit taxes are defined as the pre-tax rate of return disadvantage earned on an investment that is taxed preferentially. Implicit tax theory predicts that implicit taxes will fully offset any benefit from preferential tax treatment leading to no benefit from lower explicit taxes; however, implicit tax theory assumes perfect market competition. This paper relaxes the assumption of perfect market competition and finds that firms in industries with lower competition bear lower implicit taxes, and firms in industries with higher competition bear higher implicit taxes. These findings are consistent with firms in industries with less competition having price setting power. Further ...

Taxation, Competitiveness, And Inversions: A Response To Kleinbard, Michael S. Knoll

Faculty Scholarship at Penn Law

In this report, I argue that the inversion situation is more nuanced, complex, and ambiguous than Edward D. Kleinbard acknowledges, and I challenge Kleinbard’s claim that U.S. multinationals are on a tax par with their foreign competitors.

Why Do Publicly Listed Firms Evade Taxes: Evidence From China, Travis Chow, Bin Ke, Hongqi Yuan, Yao Zhang

Research Collection School Of Accountancy

Taking advantage of the mandatory disclosure of detected corporate tax evasions in China, we examine why publicly listed firms evade taxes. Different from most prior studies that focus on corporate income tax avoidance, we consider tax evasions related to both income taxes and non-income taxes. We also use a bivariate probit model to account for the partial observability of corporate tax evasion. Many of our regression results using the bivariate probit model are different from the results using the reduced form probit model that ignores the partial observability of tax evasion. Many of our results are also different from those ...

Taxation Of Income On Professional Team Athletes, Crystal M. Williamson

Senior Honors Theses

Taxation of income for the average person can be a daunting task. However, for professional athletes, this task becomes even more tedious. Professional athletes face the jock tax. This means that athletes have to pay taxes in every state in which they play a game, practice, and perform a service that is part of their contract. Professional athletes, like every United States (U.S.) citizen, are required to pay both federal and state income taxes. Since professional athletes are constantly traveling, their state of residence becomes even more important when allocating their income to the respective state. Many question the ...

How May The United States Leverage Fatca To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments?, William H. Byrnes

William H. Byrnes