Taxation Commons^™

Regulating Offshore Finance, William J. Moon

Faculty Scholarship

From the Panama Papers to the Paradise Papers, massive document leaks in recent years have exposed trillions of dollars hidden in small offshore jurisdictions. Attracting foreign capital with low tax rates and environments of secrecy, a growing number of offshore jurisdictions have emerged as major financial havens hosting thousands of hedge funds, trusts, banks, and insurance companies.

While the prevailing account has examined offshore financial havens as “tax havens” that facilitate the evasion or avoidance of domestic tax, this Article uncovers how offshore jurisdictions enable corporations to evade domestic regulatory law. Specifically, recent U.S. Supreme Court cases restricting the geographic …

Relationships Between Corporate Inversions And The Tax Cuts & Jobs Act, Sedona L. Clothier

Honors Theses and Capstones

No abstract provided.

Summaries For The 33rd Annual Tei-Sjsu High Tech Tax Institute, Silin Chen, June Hostetter, Sahdia Saiara, Jessica Wong, Cherry Zheng

The Contemporary Tax Journal

No abstract provided.

Defying The Tone At The Top: An Analysis On The Effects Of Board Characteristics On The Level Of Tax Avoidance Across Philippine Publicly Listed Firms, John Ryan G. Ledesma, Chester T. Herrera, Sharlene Camille A. Li, Angelo A. Unite, Ailyn A. Shi, Michael J. Sullivan

Angelo King Institute for Economic and Business Studies (AKI)

Over the years, the growing culture of tax avoidance among multinational companies around the world has shed light on the importance of improving corporate governance mechanisms. In the Philippines, poor tax collection due to tax leakages has contributed to chronic fiscal deficits in the country. The literature argues that good corporate governance mechanisms (e.g., the structure of the board of directors) play a significant role in ensuring that the management acts in the best interest of the firm and shareholders, thus eventually helping to mitigate the incidences of corporate tax avoidance. Specifically, agency theory argues that the presence of more …

Stamp Duty Issues In Singapore Corporate Practice, Vincent Ooi

Research Collection Yong Pung How School Of Law

A new dimension to the determination and computation of stamp duties payable in corporate transactions has been introduced due to the Additional Conveyance Duties (“ACD”) Regime. For companies with significant residential property holdings, liability to pay ACD potentially extends to all transactions involving the issuance, transfer or cancellation of equity interests. This paper considers the impact of ACD on several common corporate transactions in Singapore, addressing the risks practitioners may face in being blindsided by potential tax liabilities. Besides highlighting potential pitfalls, this paper explores the use of advance rulings and preferring debt financing over equity financing for tax optimisation.

Assessing The Impact Of The Philippine Sin Tax Reform Law On The Demand For Cigarettes, Myrna S. Austria, Jesson A. Pagaduan

Angelo King Institute for Economic and Business Studies (AKI)

One of the significant legislations during the Aquino Administration was Republic Act 10351, otherwise known as the Sin Tax Reform Act of 2012. Considered a landmark legislation, the law addressed the long-standing structural weaknesses of the country’s tobacco tax system. It considerably increased the specific excise tax on tobacco and tobacco products, simplified the tax structure, removed the price classification freeze and indexed the tax rates to address inflation. Prior to the reform, tobacco taxation in the country followed a complex four-tiered tax system using a tax base freeze at 1996 price levels. And since the excise tax was not …

Why Section 179(B)(3)(A)'S Business Income Limitation Does Not Apply To Partnerships And S Corporations, David Randall Jenkins Ph.D.

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal's Interview With Mr. Jim Fuller, Ophelia Ding

The Contemporary Tax Journal

No abstract provided.

Latent Semantic Analysis: A Big Data Opportunity For Tax Research, Paul D. Hutchison Ph.D., C. Elizabeth Plummer Ph.D., Cpa, Benjamin George Ph.D.

The Contemporary Tax Journal

No abstract provided.

Tax Treatment Of High-Tech Start-Up Costs, June (Yun) Hostetter Cpa

The Contemporary Tax Journal

No abstract provided.

R&D Credit Against Payroll Tax Liabilities - The Payroll Tax Credit, Sarah Yaqin Sun

The Contemporary Tax Journal

No abstract provided.

Analysis Of H.R.2551 - 115th Congress (2017-2018) - Student Loan Debt Relief Act, Soon-Young Apple, Debanjana Banerjee, Nilesh Lad, Anna Li

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal Volume 7, No. 1 - Winter 2018

The Contemporary Tax Journal

No abstract provided.

Summaries For The 2017 Irs-Sjsu Small Business Tax Institute, Ruchi Chopra Cpa, Mba, Ophelia Ding, Surbhi Doshi, Nilesh Lad Cpa, Sara Yaqin Sun

The Contemporary Tax Journal

No abstract provided.

The Emerging International Taxation Problems, James G. Yang, Victor N.A. Metallo

Department of Accounting and Finance Faculty Scholarship and Creative Works

The problems of tax evasion and tax avoidance are as old as taxes themselves. Between 2015 and 2016 alone, many U.S. multinational corporations were involved in tax disputes with the European Commission. From a historical perspective, these disputes are unprecedented as they have resulted in tremendous amount of tax penalties. The most notable case was Apple for €13 billion of unpaid tax. This article discusses what tax strategies these corporations used that caused such disputes. It specifically investigates seven corporations: Apple Inc., McDonald’s, Starbucks, Fiat, Amazon, Google, and Ikea, and elaborates on the following tax strategies: high royalties, intercompany transfer …

Leak-Driven Law, Shu-Yi Oei, Diane Ring

Faculty Scholarship

Over the past decade, a number of well-publicized data leaks have revealed the secret offshore holdings of high-net-worth individuals and multinational taxpayers, leading to a sea change in cross-border tax enforcement. Spurred by leaked data, tax authorities have prosecuted offshore tax cheats, attempted to recoup lost revenues, enacted new laws, and signed international agreements that promote “sunshine” and exchange of financial information between countries.

The conventional wisdom is that data leaks enable tax authorities to detect and punish offshore tax evasion more effectively, and that leaks are therefore socially and economically beneficial. This Article argues, however, that the conventional wisdom …

Tax Issues In The Sharing Economy: Implications For Workers, Shu-Yi Oei, Diane M. Ring

Faculty Scholarship

No abstract provided.

Limits, Transparency, And Board Independence Against Tax Avoidance, Francis R. Concepcion, Cheri Mae R. Laguinday, Trisha Amber T. Ong Hianghuy

Angelo King Institute for Economic and Business Studies (AKI)

Taxes are levied by the government primarily for public service purposes (De Leon & De Leon, 2016).However, the high tax rates and narrow tax base imposed in the Philippines become burdensome for taxpayers and also decrease total government revenue collections (Diokno, 2008). It is shown in this study that foreign ownership and customer concentration both increase the levels of corporate tax avoidance practiced by firms while board independence decreases the same. Hence, we do not support the government’s plan to ease foreign ownership restrictions through the amendment of the Constitution (Romualdez, 2017) because easing the current restrictions may entail decreased …

Dorothy Moser Medlin Papers - Accession 1049, Dorothy Moser Medlin

Manuscript Collection

(The Dorothy Moser Medlin Papers are currently in processing.)

This collection contains most of the records of Dorothy Medlin’s work and correspondence and also includes reference materials, notes, microfilm, photographic negatives related both to her professional and personal life. Additions include a FLES Handbook, co-authored by Dorothy Medlin and a decorative mirror belonging to Dorothy Medlin.

Major series in this collection include: some original 18th century writings and ephemera and primary source material of André Morellet, extensive collection of secondary material on André Morellet's writings and translations, Winthrop related files, literary manuscripts and notes by Dorothy Medlin (1966-2011), copies …

Taxing Systemic Risk, Eric D. Chason

The 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 continue to …

An Evaluation Of Tax Structure And Practices Of On Board Sales In Brazil, Gregory Altom, Fabio Campos, Haroldo De Lima, Rita Medina, Andrezza Moraes

Graduate Student Works

This study compared the tax costs between on-board sales and airport cafeterias of a mix of twenty-five products composed of beverages, fresh food and snacks in the amount that would be boarded on domestic flights between São Paulo, SP, Rio de Janeiro, RJ and Brasília, DF. The study showed that airlines are paying three times more in taxes than the airport cafeterias. The study suggested that states stop charging taxes for the transfer of unsold products on board, reducing 67% of the fees paid by airlines that practice buy on board (BoB) and guarantee a revenue gain between USD $ …

Business Tax Burdens And Tax Reform, James R. Hines Jr.

Articles

Tax reforms affect economic performance by changing incentives for business formation, expansion, and operation. The United States has the highest corporate tax rate among OECD countries in 2017, and despite offering significant additional deductions, exclusions, and tax credits, imposes the heaviest tax burdens. This paper offers a new measure of corporate tax burdens based on information in tax expenditure budgets; this measure implies that the burden of U.S. corporate taxation in 2017 is equivalent to that produced by a corporate tax rate between 31.2-34.6% without additional deductions, exclusions, or tax credits. Efficient design of a business tax system encourages activities …

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.

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.

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

The Contemporary Tax Journal

No abstract provided.

Cpa Exam Review

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.

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

The Contemporary Tax Journal

No abstract provided.

(Anti)Poverty Measures Exposed, Francine J. Lipman

Scholarly Works

Few economic indicators have more salience and pervasive financial impact on everyday lives in the United States than poverty measures. Nevertheless, policymakers, researchers, advocates, and legislators generally do not understand the details of poverty measure mechanics. These detailed mechanics shape and reshape poverty measures and the too often uninformed responses and remedies. This Article will build a bridge from personal portraits of families living in poverty to the resource allocations that failed them by exposing the specific detailed mechanics underlying the Census Bureau’s official (OPM) and supplemental poverty measures (SPM). Too often, when we confront the problem of poverty, the …