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Full-Text Articles in Taxation

Not Too Salt-Y: The Disparate Federal Income Tax Treatment Of Business And Non-Business State And Local Taxes, Michael S. Knoll Nov 2017

Not Too Salt-Y: The Disparate Federal Income Tax Treatment Of Business And Non-Business State And Local Taxes, Michael S. Knoll

Faculty Scholarship

The Tax Cuts and Jobs Act, H.R. 1, would eliminate the federal income tax deduction for nonbusiness state and local taxes while maintaining the deduction for business state and local taxes. That disparate treatment has generated a storm of negative commentary. In this short essay, I consider whether the federal tax law should allow a deduction for business state and local taxes assuming that there is no deduction for nonbusiness state and local taxes. I argue that investors and businesses, including pass-through businesses, should be allowed to deduct state and local property and sales taxes, but not general income ...


Introduction To Animal Therapy And Its Related Tax Benefits, Claudia L. Kelley, Christopher K. Eller Nov 2017

Introduction To Animal Therapy And Its Related Tax Benefits, Claudia L. Kelley, Christopher K. Eller

Journal of Counseling and Psychology

How are animals being used to improve the emotional and physical health of individuals? What are the tax implications associated with service and therapy animals? We examine these questions by providing an introduction to the subject of Animal Assisted Therapy, including how therapists and counselors are routinely using therapy animals in both individual and group treatment settings. Additionally, we discuss the potential tax savings that may be available to counselors and their clients who are using service and therapy animals. We also offer recommendations and guidance for counselors who wish to incorporate animal therapy into their treatment options.


What Is State Aid And Why Corporations Should Be Worried About It?, José Manuel Martin Coronado Nov 2017

What Is State Aid And Why Corporations Should Be Worried About It?, José Manuel Martin Coronado

José-Manuel Martin Coronado

This papers gives a deep legal analysis on the foundations of state aid applicable to the European Union based on the EU Treaty. It states that the Draft Notice of the Notion of State in 2014 was a break point to modernize it and to improve its utility to fight tax avoidance. However, many issues remain to be developed in order to make it a more effective tool against BEPS.


Taxing Systemic Risk, Eric D. Chason Nov 2017

Taxing Systemic Risk, Eric D. Chason

University of New Hampshire Law Review

A tax on the harmful elements of finance—a tax on systemic risk—would raise revenue and also lower the likelihood of future crisis. Financial institutions, which pay the tax, would try to minimize its cost by lowering their systemic risk. In theory, a tax on systemic risk is perfect policy. In practice, however, this perfect policy is unattainable. Tax laws need clear definitions to be administrable. Our current understanding of systemic risk is too abstract and too metaphorical to serve as a target for taxation.

Despite the absence of a clear definition of systemic risk, academics and policy makers ...


Addressing Personal-Income-Tax Manipulation With Tools From Psychology, Alex Rees-Jones Oct 2017

Addressing Personal-Income-Tax Manipulation With Tools From Psychology, Alex Rees-Jones

Penn Wharton Public Policy Initiative

In order to better understand the tax manipulation decision-making process—both legal uses of tax deductions and illegal tax evasion—this brief looks at the impact of gain/loss framing. Analysis of tax data confirms that tax decisions are influenced by “loss aversion.” For instance, taxpayers are more likely to pursue tax reduction activities when they make a loss smaller, as compared to when they make a gain larger. The brief looks at tools that policymakers have at their disposal for both deterring tax evasion and making exiting tax incentives maximally effective. The brief discusses instances when such gain/loss ...


Undeclared Economic Activities Of Croatian Companies Findings From A Representative Survey Of 521 Companies, Colin C. Williams Sep 2017

Undeclared Economic Activities Of Croatian Companies Findings From A Representative Survey Of 521 Companies, Colin C. Williams

Colin C Williams

This report presents the findings of a survey on undeclared economic practices undertaken by Croatian companies. In order to obtain the rigorous evidence on undeclared work in Croatia, we previously investigated citizens’ experiences with undeclared work and the practice of envelope wages. With this representative survey of 521 companies, we focus on frequency of company engagement in the undeclared economy.


Under-Declaring Work, Falsely Declaring Work: Under-Declared Employment In The European Union, Colin C. Williams, Ioana Horodnic Sep 2017

Under-Declaring Work, Falsely Declaring Work: Under-Declared Employment In The European Union, Colin C. Williams, Ioana Horodnic

Colin C Williams

Under-declared employment occurs when a formal employer pays a formal employee an official declared wage but also an additional undeclared (‘envelope’) wage in order to evade the full social insurance and tax liabilities owed. The aim of this study is to evaluate the prevalence, characteristics and distribution of this fraudulent wage practice in the EU28, to explain its existence, to provide an evidence-based evaluation of the effectiveness of different policy approaches for tackling it, and propose a set of policy recommendations.

Prevalence, characteristics and distribution of under-declared employment
To evaluate the prevalence, characteristics and distribution of under-declared employment in the ...


Before International Tax Reform, We Need To Understand Why Firms Invert, Michael S. Knoll Sep 2017

Before International Tax Reform, We Need To Understand Why Firms Invert, Michael S. Knoll

Faculty Scholarship

A wave of corporate inversions by U.S. firms over the past two decades has generated substantial debate in academic, business, and policy circles.

The core of the debate hinges on a couple of key economic questions: Do U.S. tax laws disadvantage U.S.-domiciled companies relative to their foreign competitors? And, if so, do inversions improve the competitiveness of U.S. multinational firms both abroad and at home?

There is unfortunately little, if any, empirical work directly determining whether U.S.-based MNCs are currently tax-disadvantaged compared to their foreign rivals, or measuring the amount by which (if ...


Before International Tax Reform, We Need To Understand Why Firms Invert, Michael Knoll Sep 2017

Before International Tax Reform, We Need To Understand Why Firms Invert, Michael Knoll

Penn Wharton Public Policy Initiative

A wave of corporate inversions by U.S. firms over the past two decades has generated substantial debate in academic, business, and policy circles. The core of the debate hinges on a couple of key economic questions: Do U.S. tax laws disadvantage U.S.-domiciled companies relative to their foreign competitors? And, if so, do inversions improve the competitiveness of U.S. multinational firms both abroad and at home? This brief, summarizes both old and new research that views these questions through the lens of corporations’ global effective tax rates (ETRs), and finds that the stronger case seems to ...


Tackling Undeclared Work In Southeast Europe: Knowledge-Informed Policy Responses, Colin C. Williams Aug 2017

Tackling Undeclared Work In Southeast Europe: Knowledge-Informed Policy Responses, Colin C. Williams

Colin C Williams

Ø  Undeclared work is socially accepted and widely practiced in Bulgaria, Croatia, and the FYR of Macedonia.
 
Ø  More than 1 in 5 adults in these countries acknowledge that they have bought goods and services on the undeclared economy in the prior year. More than 1 in 12 report that they have undertaken undeclared work, and more than 1 in 10 declared employees report that they receive from their employer in addition to their declared salary an additional undeclared ‘envelope’ wage.
 
Ø  But undeclared work differs across and within the three countries. For every one working undeclared due to their ...


Greypolicybrief2_Macedonia.Pdf, Colin C. Williams, Peter Rodgers, Ruslan Stefanov Aug 2017

Greypolicybrief2_Macedonia.Pdf, Colin C. Williams, Peter Rodgers, Ruslan Stefanov

Colin C Williams

KEY POINTS
Ø  Undeclared work hasdeep roots in FYR of Macedonia. 1 in 16 adults and 1 in 8 of the employed engage in undeclared work. The use of informal connections to circumvent formal institutions is practiced by 35% of Macedonians.
Ø  Formal institutions in the country are underdeveloped. Unemployment also remains unusually high compared with the EU average.
Ø  The traditional repression approach to tackling undeclared work, which has been prioritised so far by the authorities, is ineffective.
Ø  Increasing penalties and surveillance/ control should at the very least be supplemented by public awareness raising campaigns, educating citizens, and ...


Illegitimate Economic Practices In Bulgaria: Findings From A Representative Survey Of 2,005 Citizens, Colin C. Williams, Junhong Yang Jul 2017

Illegitimate Economic Practices In Bulgaria: Findings From A Representative Survey Of 2,005 Citizens, Colin C. Williams, Junhong Yang

Colin C Williams

This report presents the findings of a survey on illegitimate economic practices in Bulgaria conducted between July and October 2015. This representative survey of 2005 citizens focused on the experiences of Bulgarians with undeclared work, envelope wages and the practice of “pulling strings”, as well as on their opinion about these types of dishonest behaviour.
According to the respondents, illegitimate economic practices are strongly ingrained in Bulgarian society. According to the estimation of Schneider (2013), the undeclared economy accounts for 31% of GDP in Bulgaria in 2013, which is the highest estimation for any country in the EU-28. According to ...


Preventative Policy Measures To Tackle Undeclared Work In Croatia, Colin C. Williams Jul 2017

Preventative Policy Measures To Tackle Undeclared Work In Croatia, Colin C. Williams

Colin C Williams

This report examines the drivers of the undeclared economy in Croatia, the current organisation of the fight against undeclared work, and reviews the current and potential policy approaches and measures for tackling undeclared work in Croatia.
 
Drivers of the undeclared economy in Croatia
Recently, significant advances have been made in explaining the determinants of undeclared work. To explain undeclared work, it has been understood that every society has institutions which prescribe, monitor and enforce the ‘rules of the game’ regarding what is socially acceptable. In all societies, these institutions are of two types: formal institutions that prescribe ‘state morality’ about ...


Investor Valuations Of Japan's Adoption Of A Territorial Tax Regime: Quantifying The Direct And Competitive Effects Of International Tax Reform, Sebastien J. Bradley, Estelle Dauchy, Makoto Hasegawa Jul 2017

Investor Valuations Of Japan's Adoption Of A Territorial Tax Regime: Quantifying The Direct And Competitive Effects Of International Tax Reform, Sebastien J. 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 ...


Tackling Undeclared Work In The Construction Industry: A Learning Resource, Colin C. Williams Jul 2017

Tackling Undeclared Work In The Construction Industry: A Learning Resource, Colin C. Williams

Colin C Williams

On 3 May 2017, the European Platform Tackling Undeclared Work organised a seminar in Brussels on Tools and approaches to deal with undeclared work in the construction sector. The seminar brought together Platform members and observers from 21 EU Member States (MS) and Norway (EEA) representing labour inspectorates and social security, tax and customs authorities, as well as national and European social partner representatives from the construction sector. 
This learning resource paper describes the seminar outcomes. The first section looks at the extent and nature of undeclared work in the construction sector. This is followed by an overview of the ...


Post-Jgtrra Dividend Planning, Danny A. Pannese, Paul N. Iannone Jun 2017

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 ...


Assessment Of Under-Declared Employment In Croatia, Colin C. Williams, Miroslav Radvansky, Miroslav Stefanik Jun 2017

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

Colin C Williams

This report evaluates ‘under-declared employment’, which is the practice where a formal employer pays a formal employee an official declared wage but also an additional undeclared (envelope) wage in order to evade the full social insurance and tax liabilities owed. The aim is to evaluate the prevalence, characteristics and distribution of this fraudulent wage practice in Croatia, to explain its existence, and to provide an evidence-based evaluation of the different policy approaches for tackling it, and a set of policy recommendations. 


Cpa Exam Review May 2017

Cpa Exam Review

The Contemporary Tax Journal

No abstract provided.


Country By Country Reporting Under Beps, Fenny Lei May 2017

Country By Country Reporting Under Beps, Fenny Lei

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal's Interview Of Mr. Gary Sprague, Xuan Hong May 2017

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

The Contemporary Tax Journal

No abstract provided.


Proposition 64 Legalizes Marijuana In California But The War On Drugs Continues, Jessica Wong May 2017

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 May 2017

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

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. May 2017

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.


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 May 2017

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.


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

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

The Contemporary Tax Journal

No abstract provided.


Illegitimate Economic Practices In Fyr Macedonia, Colin C. Williams, Slavko Bezeredi May 2017

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

Colin C Williams

This report presents the findings of a survey on illegitimate economic practices in FYR Macedonia conducted between August and October 2015. This representative survey of 2,014 citizens focused on their experiences with undeclared work, envelope wages and the practice of ‘pulling strings’, as well as on their opinion about these types of non-compliant behaviour.
According to the respondents, non-compliant practices are strongly ingrained in Macedonian society. Some 35% use personal connections in order to circumvent rules and procedures, 17.7% purchase undeclared goods and services, 6.1% work in the undeclared economy and 13% of employees receive envelope wages ...


The Impact Of Increased Tax Return Reporting On Financial Statement Tax Disclosure Quality: Evidence From Irs Schedule Utp, Michelle Kim Harding May 2017

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 May 2017

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 May 2017

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

Faculty Scholarship

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.


Democracy Ends Here: U.S. Collective Bargaining Decline And An Alternative Policy Approach To Business Ownership, Sara Estep May 2017

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 ...