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Taxing Wealth Seriously, Edward J. McCaffery 2017 University of Southern California;California Institute of Tecnology

Taxing Wealth Seriously, Edward J. Mccaffery

Edward J McCaffery

The social and political problems of wealth inequality in America are severe and getting worse. A surprise is that the U.S. tax system, as is, is a significant cause of these problems, not a cure for them.  The tax-law doctrines that allow those who already have financial wealth to live, luxuriously and tax-free, or to pass on their wealth tax-free to heirs, are simple. The applicable legal doctrines have been in place for nearly a century under the income tax, the primary social tool for addressing matters of economic inequality. The analytic pathways to reform are easy to see ...


Taxing Wealth Seriously, Edward McCaffery 2016 University of Southern California;California Institute of Tecnology

Taxing Wealth Seriously, Edward Mccaffery

Edward J McCaffery

The social and political problems of wealth inequality in America are severe and getting worse. A surprise is that the U.S. tax system, as is, is a significant cause of these problems, not a cure for them.  The tax-law doctrines that allow those who already have financial wealth to live, luxuriously and tax-free, or to pass on their wealth tax-free to heirs, are simple. The applicable legal doctrines have been in place for nearly a century under the income tax, the primary social tool for addressing matters of economic inequality. The analytic pathways to reform are easy to see ...


General Electric's Tax Liability: The Case For Corporate Tax Reform, Willis L. Krumholz 2016 University of St. Thomas, Minnesota

General Electric's Tax Liability: The Case For Corporate Tax Reform, Willis L. Krumholz

University of St. Thomas Journal of Law and Public Policy

No abstract provided.


Increasing Charitable Contributions Through The Use Of Trusts, Philip P. Martin, Jr., Joseph A. Sinclitico 2016 St. John's University School of Law

Increasing Charitable Contributions Through The Use Of Trusts, Philip P. Martin, Jr., Joseph A. Sinclitico

The Catholic Lawyer

No abstract provided.


Motion For Leave To File Brief And Brief Of The National Taxpayers Union, The Nevada Manufacturers Association, The Howard Jarvis Taxpayers Foundation, Americans For Limited Government, Americans For Tax Reform, The Club For Growth, Nevada Corporate Headquarters, Inc., The Nevada Motor Transport Association, The Retail Association Of Nevada, And The Reno-Sparks Chamber Of Commerce, As Amici Curiae In Support Of Petitioners, Paul E. Salamanca 2016 University of Kentucky College of Law

Motion For Leave To File Brief And Brief Of The National Taxpayers Union, The Nevada Manufacturers Association, The Howard Jarvis Taxpayers Foundation, Americans For Limited Government, Americans For Tax Reform, The Club For Growth, Nevada Corporate Headquarters, Inc., The Nevada Motor Transport Association, The Retail Association Of Nevada, And The Reno-Sparks Chamber Of Commerce, As Amici Curiae In Support Of Petitioners, Paul E. Salamanca

Paul E. Salamanca

No abstract provided.


The Administration Of Canada’S Transfer Pricing Rules: Issues And Recommendations, Jinyan Li, Pierre Barsalou, John Oatway, François Vincent 2016 Osgoode Hall Law School of York University

The Administration Of Canada’S Transfer Pricing Rules: Issues And Recommendations, Jinyan Li, Pierre Barsalou, John Oatway, François Vincent

Jinyan Li

No abstract provided.


Taxation Of Foreign Business And Investment In The People's Republic Of China, Alex Easson, Li Jinyan 2016 Selected Works

Taxation Of Foreign Business And Investment In The People's Republic Of China, Alex Easson, Li Jinyan

Jinyan Li

Up until the last six or seven years, very little attention has been paid in the West to the tax system of the People's Republic of China ("PRC" or "China"). This is understandable since, in the immediate post-liberation years, many countries in the Western Hemisphere tried hard to pretend that the PRC did not exist at all. Following its break with the Soviet Union in 1960, China adhered firmly to a policy of self-reliance. China's opening to the West, in economic terms, did not really begin until approximately 1978. Given the type of economic system which had evolved ...


International Mobility Of Highly Skilled Workers In The Canadian Context: Tax Barriers And Reform Options, Jinyan Li 2016 Osgoode Hall Law School of York University

International Mobility Of Highly Skilled Workers In The Canadian Context: Tax Barriers And Reform Options, Jinyan Li

Jinyan Li

No abstract provided.


Comparison And Assessment Of The Tax Treatment Of Foreign Source Income In Canada, Australia, France, Germany And The United States, Jinyan Li, Brian Arnold, Nolan Sharkey 2016 Osgoode Hall Law School of York University

Comparison And Assessment Of The Tax Treatment Of Foreign Source Income In Canada, Australia, France, Germany And The United States, Jinyan Li, Brian Arnold, Nolan Sharkey

Jinyan Li

No abstract provided.


Searching For Our Fiscal Soul, Edward D. Kleinbard 2016 University of Southern California

Searching For Our Fiscal Soul, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

This is an extended version of a presentation made at TEDx Livermore 2016, the theme of which was the Economics of Empathy. Searching for Our Fiscal Soul argues that democracy is an exercise in empathy towards fellow citizens we do not know, and, if we did, might not like. We express that empathy through government spending, because that is how we actualize values that are important enough that we are willing to pay for them. This is our fiscal soul in action. Whether measured against the values we all routinely recite, or against the social environments achieved by peer countries ...


It's Tax Not Trade (Stupid), Edward J. McCaffery 2016 University of Southern California;California Institute of Tecnology

It's Tax Not Trade (Stupid), Edward J. Mccaffery

University of Southern California Legal Studies Working Paper Series

Globalization, trade and other free market policies increase wealth. But the gains from trade are not being evenly spread among all citizens. People and politicians rage against foreigners. But it is the United States tax system, not trade, that ought to change, and wealthy Americans, not workers world-wide, who should be sharing the wealth. A nd it is the form of tax, not just its rate structure, that must reform, so that capital at last bears a meaningful share of the burden.


The Trojan Horse Of Corporate Integration, Edward D. Kleinbard 2016 University of Southern California

The Trojan Horse Of Corporate Integration, Edward D. Kleinbard

University of Southern California Legal Studies Working Paper Series

The U.S. Senate Finance Committee has invested significant resources, including hearings and staff reports, to make the case for an unusual form of corporate dividend integration – a corporate dividends-paid deduction, combined with a universal shareholder dividend withholding tax collected from the firm. This proposal would not reduce the cash tax outlays of U.S. corporations in respect of distributed or retained earnings. It would not reduce the aggregate tax burdens imposed on most shareholders, and in many plausible circumstances would raise those tax costs. It is a poorly targeted response to design weaknesses in the U.S. international corporate ...


Quis Custodiet: Disestablishment And Standing To Sue, Thomas J. O'Toole 2016 St. John's University School of Law

Quis Custodiet: Disestablishment And Standing To Sue, Thomas J. O'Toole

The Catholic Lawyer

No abstract provided.


The Constitutional Nature Of The United States Tax Court, Brant J. Hellwig 2016 Washington and Lee University School of Law

The Constitutional Nature Of The United States Tax Court, Brant J. Hellwig

Brant J. Hellwig

None available.


Perspectives - Emmy Award-Winning Producer And Director Thomas Kaufman, James Hagy, Colin Pearce 2016 New York Law School

Perspectives - Emmy Award-Winning Producer And Director Thomas Kaufman, James Hagy, Colin Pearce

Rooftops Project

What makes an effective message when asking for donations to a capital project using video and streaming media? Professor James Hagy and Rooftops Team member Colin Pearce asked Emmy Award-winning producer and director Tom Kaufman after screening his remarkable two-minute video for the Playtime Project, the goal of which was to fund construction of a children’s playground for a large homeless shelter in a converted, former general hospital in the District of Columbia.


The U.S. Response To Oecd-Beps And The Eu State Aid Cases, Daniel Shaviro 2016 NYU School of Law

The U.S. Response To Oecd-Beps And The Eu State Aid Cases, Daniel Shaviro

New York University Law and Economics Working Papers

This is the slightly expanded text of a talk that the author gave on June 1, 2016, at a conference in Amsterdam that was cosponsored by NYU Law School and the Amsterdam Centre for Tax Law. The conference concerned anti-BEPS implementation in the EU, and the talk concerned the U.S. response to such efforts.


10 Observations Concerning International Tax Policy, Daniel Shaviro 2016 NYU School of Law

10 Observations Concerning International Tax Policy, Daniel Shaviro

New York University Law and Economics Working Papers

This is a slightly revised version of a lunch talk that the author gave at the National Tax Association’s 46th Annual Spring Symposium on May 12. It addresses, among other topics, why there is so little consensus regarding international tax policy, and what lessons we learn from the recent wave of inversions by U.S. companies.


Taxation As Insurance, John R. Brooks 2016 Georgetown University Law Center

Taxation As Insurance, John R. Brooks

Georgetown Law Faculty Publications and Other Works

A central yet often overlooked aspect of an income tax is that it acts as insurance against the risk of low income. Because a person’s payments to government are a function of income, he can be assured that in a time of low income, his tax payments will decrease and transfers will increase, while the standard benefits of governments continue to flow. Because everyone, no matter how successful, faces some risk of lost income, that assurance provides us an insurance benefit, even if our income never actually drops.


International Tax Implications Of The Organisation For Economic Co-Operation And Development Proposal To Neutralize Hybrid Mismatch Arrangements, Dean Harris 2016 The Catholic University of America, Columbus School of Law

International Tax Implications Of The Organisation For Economic Co-Operation And Development Proposal To Neutralize Hybrid Mismatch Arrangements, Dean Harris

Catholic University Law Review

The Organisation for Economic Co-operation and Development (OECD) has developed a sixteen part plan titled Base Erosion and Profit Shifting (BEPS). This comment focuses on the second part of that plan; Neutralizing Hybrid Mismatch Arrangements. Mismatches have become a useful tool for corporations to achieve double non-taxation in various jurisdictions. The comment begins by laying the groundwork of what a hybrid mismatch arrangement is and the current problems and complications with them in international tax. Next, this comment addresses various jurisdictional approaches to mismatches, including: Ireland, The United Kingdom, The United States, and Denmark. The paper moves forward onto a ...


Give Taxpayers A Break: Putting The Reliance Element Back Into The Reasonable Reliance And Good Faith Defense, Ronald Z. Domsky 2016 Selected Works

Give Taxpayers A Break: Putting The Reliance Element Back Into The Reasonable Reliance And Good Faith Defense, Ronald Z. Domsky

Ronald Z. Domsky

No abstract provided.


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