A Review Of The Proposals For Taxation Of Profits Of Businesses In The Digitalized Economy,
2019
The University of Western Ontario
A Review Of The Proposals For Taxation Of Profits Of Businesses In The Digitalized Economy, Chukwuebuka Stanley Ndibe
Master of Laws Research Papers Repository
The advent of information technology and digitalization has changed and continues to change everyday life, including the manner in which business operations are carried out. Years back, to run a taxi business, you would need to own vehicles and employ drivers. Today, some digitalized businesses are able to operate the same business by just owning a digital interface and related intellectual property rights. This change in the way things are done has significant impact on traditional legal systems. In the realm of tax law, digitalization has impacted on traditional international tax rules including the threshold for allocating taxing rights. In. …
Toward A 21st-Century International Tax Regime,
2019
University of Michigan Law School
Toward A 21st-Century International Tax Regime, Reuven S. Avi-Yonah
Law & Economics Working Papers
The OECD has been struggling to respond to countries that wish to tax large US technology companies on the basis of where their consumers live. The current OECD work program on digitalization is unlikely to produce a stable consensus or prevent countries from following the lead of France, India, Italy and the United Kingdom toward digital services taxes. The United States response should not be to target French, Indian, Italian or British companies for retaliation. Instead, the United States should consider adopting a sales-based formulary apportionment (SFA) solution that would apply to all large enterprises. Such a move is more …
Interest Deductibility And International Taxation In Canada After Beps Action 4,
2019
Allard School of Law at the University of British Columbia
Interest Deductibility And International Taxation In Canada After Beps Action 4, David G. Duff
All Faculty Publications
Among the ways in which multinational enterprises (MNEs) can shift profits from one jurisdiction to another in order to minimize taxes, one of the most simple and widely-employed involves the payment of interest to related parties and third parties. For these reasons, it is not surprising that the Organisation for Economic Cooperation and Development’s Action Plan on Base Erosion and Profit Shifting (BEPS) identified the deduction of interest and other financial payments as a significant source of BEPS concerns, and that BEPS Action 4 was charged with developing “recommendations regarding best practices in the design of rules to prevent base …
Response To 'Reverse Al Capone-Ism' And The Tax Treatment Of Marijuana Businesses,
2019
University of Michigan Law School
Response To 'Reverse Al Capone-Ism' And The Tax Treatment Of Marijuana Businesses, Douglas A. Kahn, Howard J. Bromberg
Other Publications
Mr. Silverberg’s comment stresses that the proponents of the legalization of marijuana have not been able to convince Congress to legalize it, and so it is appropriate for Congress to penalize trafficking in that drug. Apparently, he sees our contention that the penalty adopted in I.R.C. § 280E is irrational and contravenes established punitive jurisprudence as a backdoor attempt to accomplish indirectly, by weakening the penalties on the marijuana businesses, what has not been able to be accomplished by those seeking its federal legalization. That was not the motive for our proposal and is not a fair reading of our …
Response To Dude, Where's My Deduction?,
2019
University of Michigan Law School
Response To Dude, Where's My Deduction?, Douglas A. Kahn, Howard J. Bromberg
Other Publications
Mr. Pullin’s thesis is that marijuana should be excluded from § 280E when it is operated legally under state law. However, his preferred solution is that the federal government remove marijuana from Schedules I and II of the Controlled Substances Act of 1970 (CSA), thereby legalizing it for federal law purposes. Either action would exclude the marijuana business from § 280E.
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018,
2019
San Jose State University
H.R. 285 (116th Congress) - The Mortgage Debt Tax Forgiveness Act Of 2018, Inna Ostrovsky, Joanna Levasseur
The Contemporary Tax Journal
No abstract provided.
Fun Tax Facts,
2019
San Jose State University
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019,
2019
San Jose State University
The Contemporary Tax Journal Volume 8, No. 2 – Summer 2019
The Contemporary Tax Journal
No abstract provided.
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill,
2019
San Jose State University
The Contemporary Tax Journal’S Interview With Ms. Claudia Hill, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
Front Matter (Letter From The Editor, Masthead, Etc.),
2019
San Jose State University
Front Matter (Letter From The Editor, Masthead, Etc.)
The Contemporary Tax Journal
No abstract provided.
Summaries From The 34th Annual High Tech Tax Institute,
2019
San Jose State University
Summaries From The 34th Annual High Tech Tax Institute, Amy Yue Cpa, Langzun Li, Rachana Khandelwal, Nam Nguyen
The Contemporary Tax Journal
No abstract provided.
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones,
2019
San Jose State University
Section 1400z-2 - Special Rules For Capital Gains Invested Opportunity Zones, Inna Ostrovsky
The Contemporary Tax Journal
No abstract provided.
Roger Cpa Review Questions,
2019
San Jose State University
Roger Cpa Review Questions, Roger Philipp Cpa, Cgma
The Contemporary Tax Journal
No abstract provided.
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute,
2019
San Jose State University
Summaries Of The 7th Annual Irs Sjsu Small Business Tax Institute, Chen Chen, Liwei Bi, Surbhi Doshi
The Contemporary Tax Journal
No abstract provided.
South Dakota V. Wayfair: Analysis And State Reaction,
2019
East Carolina Unversity
South Dakota V. Wayfair: Analysis And State Reaction, Andrew M. Wasilick, Dan L. Schisler Phd., Cpa
The Contemporary Tax Journal
No abstract provided.
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress),
2019
San Jose State University
First-Time Homebuyer Credit Act Of 2018 S.3364 (115th Congress), Langzun Li
The Contemporary Tax Journal
No abstract provided.
A Georgist Perspective Of Petroleum Taxation,
2019
Indiana University Maurer School of Law
A Georgist Perspective Of Petroleum Taxation, Joseph Leeson
Indiana Journal of Global Legal Studies
Over a century ago, the town of Arden, Delaware, was founded on a unique single-tax-community system that radically altered the popular concept of land ownership. This system was premised on concepts developed by a man few know today but who was a major figure in economics during the 1800s, Henry George. George's public finance theory has been described as having received "intermittent attention over the years, with many eminent names in economics making at least a passing comment, but it has seen comparably little action in the policy debate arena and has been largely ignored by the modern era of …
If Not Now, When? U.S. Tax Treaties With Latin America After Tcja,
2019
University of Michigan Law School
If Not Now, When? U.S. Tax Treaties With Latin America After Tcja, Reuven S. Avi-Yonah
Articles
Since the 1990s, the US tax treaty network has expanded to include most large developing countries. However, there remains a glaring exception: The US only has two tax treaties in Latin America (Mexico and Venezuela), and one pending tax treaty (Chile). The traditional explanation for why the US has no treaty with, for example, Argentina or Brazil is the US refusal since 1957 to grant tax sparing credits to developing countries. Before the Tax Cuts and Jobs Act of 2017 (TCJA), this explanation was wrong, because the combination of deferral and cross-crediting meant that tax holidays in a source country …
Toward A 21st-Century International Tax Regime,
2019
University of Michigan Law School
Toward A 21st-Century International Tax Regime, Reuven S. Avi-Yonah, Kimberly A. Clausing
Articles
The international tax regime is almost a century old, and it is showing its age. In recent decades, the regime could be maintained despite increasing evidence that some of its key components, such as the arm’s-length standard or permanent establishment threshold, were unfit for a 21st-century economy. However, starting with the U.K. diverted profits tax (2015), Australia’s multinational anti-tax-avoidance law (2015), and India’s equalization levy (2016), it has become clear that many countries are unwilling to live with a situation in which large U.S. technology companies (such as Amazon, Apple, Facebook, Google, and Netflix) earn billions in profits by exploiting …
Executive Compensation In The Charitable Sector: Beyond The Tax Cuts And Jobs Act,
2019
Vanderbilt University Law School
Executive Compensation In The Charitable Sector: Beyond The Tax Cuts And Jobs Act, Lauren Rogal
Vanderbilt Law School Faculty Publications
The Tax Cuts and Jobs Act of 2017 (“TCJA”) reformed charity executive compensation for the first time in decades, introducing an across-the-board excise tax on compensation over $1 million.1 Its enactment represents a significant step toward securing accountability for the use of the charitable tax exemption under Section 501(c)(3) of the Internal Revenue Code. These organizations receive preferential tax treatment to subsidize their provision of socially beneficial outputs that would otherwise be undersupplied. Overcompensation of charity executives subverts this purpose by diverting those subsidies for private gain and undermining public confidence in the charitable sector.
With the enactment of the …
