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Articles 1 - 30 of 67
Full-Text Articles in Law
Toolkit For The Evaluation Of Crypto Tax Risks (Outline), Vincent Ooi
Toolkit For The Evaluation Of Crypto Tax Risks (Outline), Vincent Ooi
Research Collection Yong Pung How School Of Law
This Toolkit seeks to provide a practical, structured framework for the identification and assessment of crypto tax risks that can be used by tax administrations. It has three main parts. Firstly, an introduction to the Toolkit and how it should be used. Secondly, a series of questionnaires to complete. Thirdly, a commentary to provide additional context and details on each part of the Toolkit and its application. As tax administrations go through the questionnaires, they can rely on the Commentary to complement their existing knowledge and expertise to accurately identify the crypto tax risks facing their domestic tax systems.
'99-To-1’ Property Deals: Stamp Duty Avoidance Or Honest Mistake, Vincent Ooi
'99-To-1’ Property Deals: Stamp Duty Avoidance Or Honest Mistake, Vincent Ooi
Research Collection Yong Pung How School Of Law
This article explains in detail the legal issues surrounding the recent ABSD audit and how exactly the general anti-avoidance rule and the stamp duty avoidance surcharge in the Stamp Duties Act 1929 can be invoked by the IRAS.The article highlights the fact that it may not be enough for a property buyer to show that the '99-to-1' holding was intended to enable the buyer to qualify for a home loan and not 'for stamp duty avoidance'. The property buyer must be able to answer the additional question of why the transfer of the property is 'staggered' in two stages and …
A New Framework For Taxing Cryptocurrencies, Reuven S. Avi-Yonah, Mohanad Salaimi
A New Framework For Taxing Cryptocurrencies, Reuven S. Avi-Yonah, Mohanad Salaimi
Articles
This Article explores the tax law challenges associated with the taxation of cryptocurrencies and offers proposals to address such challenges. The Article addresses the proper tax treatment of different cryptocurrency transactions and activities. It examines various aspects associated with the taxation of cryptocurrency through its life cycle, starting from earning cryptocurrency, through its disposal or exchange. The Article also examines the tax treatment of two special crypto events, hard forks and airdrops. Specifically, this Article describes a proposal to tax cryptocurrencies based on their unique features. It argues that various ways of earning or receiving crypto tokens (for example, mining …
Pop & Perjury: The Irs Valuation War With The Estate Of Michael Jackson, Beckett Cantley, Geoffrey Dietrich
Pop & Perjury: The Irs Valuation War With The Estate Of Michael Jackson, Beckett Cantley, Geoffrey Dietrich
The University of New Hampshire Law Review
When Michael Jackson died unexpectedly in Los Angeles, California, on June 25, 2009, his career and earnings were nearing an all-time low. Plagued by past sexual abuse allegations, scandals, and questionable health, Michael Jackson’s personal finances were purported to be in complete disarray. However, following his unexpected death, the value of his estate, which was reported to be near to nothing, swelled as the world remembered his beloved contributions to the world and began to purchase accordingly. Sales of Michael Jackson’s music began to soar high. The estate’s value soared even higher as it signed licensing agreements and released new …
An Automation Tax- Adopt With Caution, Vincent Ooi
An Automation Tax- Adopt With Caution, Vincent Ooi
Research Collection Yong Pung How School Of Law
The post highlights three main issues that may result from the rapid and widespread automation of jobs: 1) declining tax revenues; 2) inequitable distribution of gains and losses from automation; and 3) social costs of job displacement, such as social support and retraining programmes for displaced workers.An automation tax may be imposed on a temporary basis to manage (slow) the rate of displacement of workers due to the adoption of automation technologies, but should not be a permanent feature. Otherwise, there will be a risk of loss of competitiveness in the long-term, possibly resulting in even greater economic harm.One main …
New Assets, (Largely) Same Old Rules: The Taxation Of Digital Tokens, Vincent Ooi
New Assets, (Largely) Same Old Rules: The Taxation Of Digital Tokens, Vincent Ooi
Research Collection Yong Pung How School Of Law
In this blog post, I highlight the fact that across jurisdictions, tax provisions specifically drafted to address the taxation of digital tokens are still quite rare, meaning that existing orthodox tax rules will have to be applied. However, care must be taken when applying tax provisions and one must be aware of the limits of "reasoning by analogy".Some tax provisions make reference to specific assets or asset classes and it cannot be assumed that digital tokens which look very similar to these assets will inevitably fall under those provisions. For example, no matter how much a digital payment token looks …
Making Money From Cryptocurrency? The Taxman May Call On You, Hern Kuan Liu, Vincent Ooi
Making Money From Cryptocurrency? The Taxman May Call On You, Hern Kuan Liu, Vincent Ooi
Research Collection Yong Pung How School Of Law
Miners, forgers, hobbyists, traders – different rules apply. Just don’t assume crypto investment is somehow immune to taxation.
Tax Considerations For Funds Structuring In Asia, Vincent Ooi
Tax Considerations For Funds Structuring In Asia, Vincent Ooi
Research Collection Yong Pung How School Of Law
Tax considerations play a major role in the decisions of fund managers of where to base their funds. The highly mobile nature of capital has resulted in tax competition, leading to several host jurisdictions for funds in Asia (Hong Kong, Singapore, Labuan, and the BVI) having very similar tax characteristics in terms of low effective corporate income tax rates; no capital gains taxes; no exit taxes; a single tier of taxation; and generally no withholding taxes. Other ways in which jurisdictions have attempted to distinguish themselves include a strong Double Tax Agreement network, certainty on the taxation of the carried …
Will Create Resolve The Philippines’ Unemployment Woes Amidst The Covid-19 Pandemic?, Krista Danielle Yu, Marites Tiongco
Will Create Resolve The Philippines’ Unemployment Woes Amidst The Covid-19 Pandemic?, Krista Danielle Yu, Marites Tiongco
Angelo King Institute for Economic and Business Studies (AKI)
In response to the COVID-19 pandemic, there is a proposal to amend the Corporate Income Tax and Incentives Reform Act (CITIRA) into the Corporate Recovery and Tax Incentives for Enterprises Act (CREATE) Act. The proposed amendments are as follows: (a) An immediate five percentage point cut into the corporate income tax (CIT) rate starting July 2020; (b) Maintaining for up to nine years the status quo for registered business activities enjoying the 5% tax on gross income earned (GIE) incentive; and (c) More flexibility for the President to grant a combination of fiscal and non-fiscal incentives, which will be critical …
Law School News: Remembering Rwu Laws Founding Dean 9-10-2019, Roger Williams University School Of Law
Law School News: Remembering Rwu Laws Founding Dean 9-10-2019, Roger Williams University School Of Law
Life of the Law School (1993- )
No abstract provided.
Proposed Reforms To Singapore Goods And Services Taxation In The Digital Economy, Hern Kuan Liu, Vincent Ooi
Proposed Reforms To Singapore Goods And Services Taxation In The Digital Economy, Hern Kuan Liu, Vincent Ooi
Research Collection Yong Pung How School Of Law
With the rapid development of the digital economy and the increasing importance of GST as a source of tax revenue, the Singapore Government has proposed several reforms to tighten the collection of tax revenue and tap its tax base more efficiently. The reforms focus on activating the currently dormant “reverse charge” mechanism to collect GST on supplies of services “imported” by businesses; creating an “overseas vendor registration regime” to catch digital products “imported” by individuals; and clarifying the “place of supply” requirement for supplies of digital products. This article considers the reforms from the perspective of a foreign business that …
Stamp Duty Issues In Singapore Corporate Practice, Vincent Ooi
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.
Limits, Transparency, And Board Independence Against Tax Avoidance, Francis R. Concepcion, Cheri Mae R. Laguinday, Trisha Amber T. Ong Hianghuy
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 …
Before International Tax Reform, We Need To Understand Why Firms Invert, Michael S. Knoll
Before International Tax Reform, We Need To Understand Why Firms Invert, Michael S. Knoll
All 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 any) U.S.-based MNCs improve their competitive position …
The Tax Treatment Of Tokens: What Does It Betoken?, David J. Shakow
The Tax Treatment Of Tokens: What Does It Betoken?, David J. Shakow
All Faculty Scholarship
Digital tokens have been used to raise substantial amounts of money. But little attention has been paid to the tax consequences surrounding their issuance and sale. There are significant potential tax liabilities lurking in the use of digital tokens. But, because of the anonymity inherent in the blockchain structures used for the issuance of tokens and payments for them, there is a significant question as to whether those tax liabilities will ever be collected.
1919 And 1920, State Board Of Equalization Report
1919 And 1920, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1921 And 1922, State Board Of Equalization Report
1921 And 1922, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1923 And 1924, State Board Of Equalization Report
1923 And 1924, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1925 And 1926, State Board Of Equalization Report
1925 And 1926, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1927 And 1928, State Board Of Equalization Report
1927 And 1928, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1911 And 1912, State Board Of Equalization Report
1911 And 1912, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1913 And 1914, State Board Of Equalization Report
1913 And 1914, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1915 And 1916, State Board Of Equalization Report
1915 And 1916, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
1917 And 1918, State Board Of Equalization Report
1917 And 1918, State Board Of Equalization Report
California Board of Equalization Reports
Written report concerning activities of Board of Equalization and statistical tables specific to California agricultural, livestock and viticulture for each county. (To view complete report containing all statistical tables, see URL: https://catalog.hathitrust.org/Record/100187327 or https://catalog.hathitrust.org/Record/007150404.)
Property Or Currency? The Tax Dilemma Behind Bitcoin, Scott A. Wiseman
Property Or Currency? The Tax Dilemma Behind Bitcoin, Scott A. Wiseman
Utah Law Review
At Bitcoin’s peak in November 2013, there were 93,000 global transactions made in a single day. These users purchased everyday items such as personal services, food, and real estate. This alone suggests that Bitcoin is not primarily used as a long-term investment tool, but rather is used as a currency and a vehicle for global transactions. Congress and the IRS should regulate it accordingly. Representative Stockman’s Virtual Currency Reform Act offered an attempt to negate the IRS decision and officially classify Bitcoin and other virtual currencies as currency instead of property. A tax reclassification would alleviate typical users’ many inconveniences …
The Common Knowledge Of Tax Abuse, Mark P. Gergen
The Common Knowledge Of Tax Abuse, Mark P. Gergen
Mark P. Gergen
No abstract provided.
The Influence Of Tax Law On Securities Innovation In The United States: 1981-1997, Mark P. Gergen, Paula Schmitz
The Influence Of Tax Law On Securities Innovation In The United States: 1981-1997, Mark P. Gergen, Paula Schmitz
Mark P. Gergen
No abstract provided.
Can Wealth Taxes Be Justified, Eric Rakowski
Determining A Partner's Share Of Unrealized Receivables At The Liquidation Of The Partner's Interest, Stephen Utz
Determining A Partner's Share Of Unrealized Receivables At The Liquidation Of The Partner's Interest, Stephen Utz
Stephen Gerard Utz
Partnership law allows partners great freedom to vary the terms on which they share partnership profits from different sources. Partnership tax law, however, seems to presume, for purposes of the collapsible partner rules, that partners will share the revenue from the collection of receivables always in proportion to the value of their partnership interests. This counterfactual presumption exposes both the government and partner/taxpayers to unfortunate consequences. A substance-over-form approach to the attribution of unrealized receivables would certainly be unworkable, because too costly and intrusive to administer. Something between substance-over form and form-over-substance would best implement the policy of Subchapter K …
Revenue, U.S. Government, Bert Chapman
Revenue, U.S. Government, Bert Chapman
Libraries Faculty and Staff Scholarship and Research
Provides a historical overview of U.S. Government revenue receipts and spending during the early years of national history. Presents revenue generation statistics, information on revenue sources, and information on domestic and international political and economic factors affecting government revenue receipts.