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Articles 1 - 20 of 20
Full-Text Articles in Law
The U.S. Consumption Tax: Evolution, Not Revolution, Daniel Goldberg
The U.S. Consumption Tax: Evolution, Not Revolution, Daniel Goldberg
Daniel S. Goldberg
The article expresses the view that the current Internal Revenue Code has evolved into a hybrid income tax and consumption tax. It begins by explaining the difference between an income tax and a consumption tax and provides the backgrounds of the alternative forms of consumption tax: (1) consumed income, (2) yield exemption, and (3) point-of-sale taxation. Under the consumed income tax model of consumption tax, the individual taxpayer includes all items of income, both from labor and from capital, in its tax base, and then subtracts or deducts the portion of that income that he saves or invests. The resulting …
Government Precommitment To Tax Incentive Subsidies: The Impact Of United States V. Winstar Corp. On Retroactive Tax Legislation, Daniel S. Goldberg
Government Precommitment To Tax Incentive Subsidies: The Impact Of United States V. Winstar Corp. On Retroactive Tax Legislation, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
Interest Elements In Tax Planning, Daniel S. Goldberg
Interest Elements In Tax Planning, Daniel S. Goldberg
Daniel S. Goldberg
This article discusses how interest has been and is being used in tax planning. The tax planning techniques using interest include charging too little interest or none at all, recalssifying interest as principal and allocating interest among time periods to optimize the tax consequences to the parties. The issues raised by these tax planning techniques go to the heart of the tax system. They suggest inadequacies in the development of the case law and in conventional tax thinking. The unifying principal is the divergence between the possible tax consequences and the clear economic consequences of each of the transactions. The …
E Tax: The Flat Tax As An Electronic Credit Vat, Daniel S. Goldberg
E Tax: The Flat Tax As An Electronic Credit Vat, Daniel S. Goldberg
Daniel S. Goldberg
The article builds on the Hall-Rabushka Flat Tax and proposes a consumption tax called the “E Tax,” which is an electronically collected credit invoice VAT. The Hall-Rabushka Flat Tax is a two-tier consumption tax that is based on a subtraction method VAT. The Hall-Rabushka nuance, however, allows a deduction for wages as if they were purchases of materials by the employer. Wage earners would be taxed on those wages at rates that could be set as graduated or flat, with or without a zero rate or bracket amount and with or without personal exemptions and deductions. Hall and Rabushka proposed …
Considering A Consumption Tax, Daniel S. Goldberg
Considering A Consumption Tax, Daniel S. Goldberg
Daniel S. Goldberg
A combination of electronic commerce and the "Flat Tax" could eliminate the IRS as we know it.
The Kingdom Of Pal: A Parable Of Tax Shelters And The Passive Activity Loss Rules, Daniel S. Goldberg
The Kingdom Of Pal: A Parable Of Tax Shelters And The Passive Activity Loss Rules, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
Nonrecourse Debt In Excess Of Fair Market Value: The Confluence Of Basis, Realization, Subchapter K And The Need For Consistency, Daniel S. Goldberg
Nonrecourse Debt In Excess Of Fair Market Value: The Confluence Of Basis, Realization, Subchapter K And The Need For Consistency, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
Open Transaction Treatment For Deferred Payment Sales After The Installment Sales Act Of 1980, Daniel S. Goldberg
Open Transaction Treatment For Deferred Payment Sales After The Installment Sales Act Of 1980, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
The Tax Treatment Of Limited Liability Companies: Law In Search Of Policy, Daniel S. Goldberg
The Tax Treatment Of Limited Liability Companies: Law In Search Of Policy, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
E-Vat: An Electronically Collected Progressive Consumption Tax, Daniel S. Goldberg
E-Vat: An Electronically Collected Progressive Consumption Tax, Daniel S. Goldberg
Daniel S. Goldberg
This report proposes replacing the income tax with an electronic, progressive consumption tax that couples a credit-method VAT (modified for wages) with a progressive wage tax. I have called this proposal e-VAT (a convenient contraction for an electronic value added tax), because it is based on a business-level-credit VAT and can be collected automatically and electronically at the point of sale. The essential advantage of e-VAT over the Hall-Rabushka flat tax is that e-VAT’s use of a credit VAT as its foundation facilitates automatic and electronic collection of the tax. A credit VAT lends itself to electronic monitoring and auditing …
E-Tax: Fundamental Tax Reform And The Transition To A Currency-Free Economy, Daniel S. Goldberg
E-Tax: Fundamental Tax Reform And The Transition To A Currency-Free Economy, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
The Aches And Pains Of Transition To A Consumption Tax: Can We Get There From Here?, Daniel S. Goldberg
The Aches And Pains Of Transition To A Consumption Tax: Can We Get There From Here?, Daniel S. Goldberg
Daniel S. Goldberg
This article discusses probably the most significant obstacle to the adoption of a consumption tax: the negative effects on existing wealth that the transition from the income tax to most forms of a consumption tax would have. The Congressional Budget Office in its 1997 study posed the question, “How to Get There from Here.” The difficulty with transition and the changes in the tax law since the CBO study, however, prompt the more basic question: “Can we get there from here?” This article deals with this question by examining the effects of transition on existing wealth under a variety of …
Fair Market Value In The Tax Law: Replacement Value Or Liquidation Value, Daniel Goldberg
Fair Market Value In The Tax Law: Replacement Value Or Liquidation Value, Daniel Goldberg
Daniel S. Goldberg
No abstract provided.
To Praise The Amt Or To Bury It, Daniel S. Goldberg
To Praise The Amt Or To Bury It, Daniel S. Goldberg
Daniel S. Goldberg
The alternative minimum tax (AMT) has recently become a cause célèbre because many more taxpayers are now subject to it than originally envisioned at the time of its enactment in 1969 (and, indeed, than after any of its several modifications over the years). As such, it has been discussed and criticized in the press and by tax professionals and academics, most recently in Tax Notes by four former Internal Revenue Service commissioners who advocated scrapping it entirely. The criticism has questioned the wisdom of the inadvertent expansion of the AMT in coverage, that is, the number of taxpayers who will …
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel Goldberg
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel Goldberg
Daniel S. Goldberg
No abstract provided.
The Passive Activity Loss Rules: Planning Considerations, Techniques, And A Foray Into Never-Never Land, Daniel S. Goldberg
The Passive Activity Loss Rules: Planning Considerations, Techniques, And A Foray Into Never-Never Land, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
Choice Of Entity For A Venture Capital Start-Up: The Myth Of Incorporation, Daniel S. Goldberg
Choice Of Entity For A Venture Capital Start-Up: The Myth Of Incorporation, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
Lifetime Gifts - A Quantitative Approach, Roger A. Pies, Daniel S. Goldberg
Lifetime Gifts - A Quantitative Approach, Roger A. Pies, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.
Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel Goldberg
Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel Goldberg
Daniel S. Goldberg
No abstract provided.
Recent Approaches To The Trade Or Business Requirement Of Section 174: Unauthorized Snow Removal, Daniel S. Goldberg
Recent Approaches To The Trade Or Business Requirement Of Section 174: Unauthorized Snow Removal, Daniel S. Goldberg
Daniel S. Goldberg
No abstract provided.