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Articles 1 - 4 of 4
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.
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Should General Utilities Be Reinstated To Provide Partial Integration Of Corporate And Personal Income—Is Half A Loaf Better Than None?, Douglas A. Kahn
Articles
The General Utilities doctrine is the name given to the now largely defunct tax rule that a corporation does not recognize a gain or a loss on making a liquidating or nonliquidating distribution of an appreciated or depreciated asset to its shareholders. The roots of the doctrine, can be traced to a regulation promulgated in 1919 that denied realization of gain or loss to a corporation when making a liquidating distribution of an asset in kind. No regulatory provision existed which specified the extent to which realization would or would not be triggered by a nonliquidating distribution such as a …
The Low-Income Housing Tax Credit: A Poor Solution To The Housing Crisis, Janet Stearns
The Low-Income Housing Tax Credit: A Poor Solution To The Housing Crisis, Janet Stearns
Articles
No abstract provided.