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Genes As Tags: The Tax Implications Of Widely Available Genetic Information, Kyle D. Logue, Joel B. Slemrod
Genes As Tags: The Tax Implications Of Widely Available Genetic Information, Kyle D. Logue, Joel B. Slemrod
Law & Economics Working Papers Archive: 2003-2009
This paper examines how progress in genetics' specifically, the proliferation of knowledge about the human genome' may influence the feasibility and desirability of a tax that is based on individual human endowments or ability. The paper explores various forms that such a genetic endowment tax-and-transfer regime might take and identifies some of the benefits and costs of such a regime. The authors take no position on whether a genetic endowment tax would be desirable or not. However, one contribution of the paper is to observe that current law in the U.S., which restricts the use of genetic information by insurers …
Business Income (Article 7 Oecd Mc), Reuven S. Avi-Yonah, Kimberly A. Clausing
Business Income (Article 7 Oecd Mc), Reuven S. Avi-Yonah, Kimberly A. Clausing
Law & Economics Working Papers Archive: 2003-2009
The 2006 OECD Report on attribution of profits to permanent establishments states that its recommendation “was not constrained by either the original intent or by the historical practice and interpretation of Article 7.” Moreover, the Report recommends a redrafting of both the Article itself and the Commentary. Given this, it seems appropriate to begin by asking: If we were working on a clean slate, what would be the best way to tax MNEs at source in the light of 21st century business practices?
The beginning point has to be that a modern MNE does not operate as if its constituent …
A Proposal To Adopt Formulary Apportionment For Corporate Income Taxation: The Hamilton Project, Reuven S. Avi-Yonah, Kimberly Clausing
A Proposal To Adopt Formulary Apportionment For Corporate Income Taxation: The Hamilton Project, Reuven S. Avi-Yonah, Kimberly Clausing
Law & Economics Working Papers Archive: 2003-2009
The current system of taxing the income of multinational firms in the United States is flawed across multiple dimensions. The system provides an artificial tax incentive to earn income in low-tax countries, rewards aggressive tax planning, and is not compatible with any common metrics of efficiency. The U.S. system is also notoriously complex; observers are nearly unanimous in lamenting the heavy compliance burdens and the impracticality of coherent enforcement. Further, despite a corporate tax rate one standard deviation above that of other OECD countries, the U.S. corporate tax system raises relatively little revenue, due in part to the shifting of …