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Full-Text Articles in Law
Taxation And U.S. Multinational Investment, James R. Hines Jr.
Taxation And U.S. Multinational Investment, James R. Hines Jr.
Articles
In 1985, nonbank U.S. multinational companies employed 24.5 million workers, had worldwide sales of almost $3.5 trillion, and net income of $150 billion on assets of $4.2 trillion. The foreign (non-U.S.) affiliates of these companies had 6.4 million employees, $900 billion of those sales, and $43 billion of net income, with assets of $838 billion. United States multinationals accounted for roughly three-quarters of total American merchandise exports in 1985 and half of total imports, with approximately 40 percent of each category arising from transfers within U.S. multinationals between American parent firms and their own foreign affiliates. And 1985 is widely …
The Tax Treatment Of Qualified Plans: A Classic Defense Of The Status Quo, Edward A. Zelinsky
The Tax Treatment Of Qualified Plans: A Classic Defense Of The Status Quo, Edward A. Zelinsky
Articles
The current tax treatment of qualified pension and profit sharing plans has been criticized by commentators as an unfair and expensive tax expenditure. In this Article, Professor Zelinsky challenges this characterization and defends the current treatment of qualified plans on the ground that it is at least as attractive as its alternatives and superior to many of them. After evaluating the current treatment and the alternatives under the criteria of measurability, administrability, liquidity, equity, and simplicity, Professor Zelinsky concludes that the present treatment of qualified plans can be viewed as an acceptable part of a normative income tax.