Biometrics, Certified Software Solutions, and the Japanese Consumption Tax: a Proposal For the Tax Commission

Richard Ainsworth
Significant change is anticipated in the Japanese Consumption Tax. This is the conclusion of the Japanese Tax Commission in its mid-term report, presented to Prime Minister Junichiro Koizumi on June 17, 2003. When the Tax Commission’s Chairman, Professor Hiromitsu Ishi,[1]submitted A Sustainable Tax System for Japan’s Aging Society[2]the Commission indicated that it was responding to a“state of crisis…[brought...

Tax Fraud in The Sales Tax: Zappers – What Are They? How Can Puerto Rico Block Them?

Richard Ainsworth
The Sales and Use Tax is an essential part of Puerto Rico's revenue profile. Effective only recently (November 15, 2006) the Impuesto a las Ventas y Uso (IVU)[1] was expected to raise between $2.3 and $1.05 billion annually,[2] and has already become the Commonwealth's fourth largest revenue source.[3] Actual revenue results for 2007-2008 came in at $1.1 billion,[4] which admittedly is closer to the low end than the high...

Ain’t Charity: Disallowing Deductions for Kept Resources

Calvin Johnson
The two proposals in this article have a common theme: Accounting for taxable income should reflect money a taxpayer has kept for his own self-serving uses. A charitable deduction is reasonable when the taxpayer has forfeited resources to others, but not when the taxpayer has consumed resources for self-use. Providing a subsidy by exempting resources that a taxpayer has kept for himself is not a reasonable way to promote...

The United States’ Experience with Energy-Based Tax Incentives: The Evidence Supporting Tax Incentives for Renewable Energy

Mona Hymel
Developing sustainable markets for renewable energy technologies presents complex challenges. Financial, institutional and informational obstacles impede advancement of these technologies. Tax incentives are often utilized to assist policy makers in dealing with these challenges.[1] Because tax incentives and subsidies generally decrease governmental revenues, understanding their costs and benefits is critical in determining...

Competition Between Tax Havens: Does Geographic Distribution Matter?

Luisa Blanco
Written by: Luisa Blanco and Cynthia Rogers 1. Introduction Over the past decade, economic globalization has led to a significant increase in capital mobility and a corresponding increase in demand for tax haven operations. In fact, total liabilities for a sample of 20 tax havens grew by 154 percent between 1998 and 2006 (Kudrle, 2008). Fearing the harmful impacts of tax haven policies, OECD countries launched the...

A Policy Analysis Of Michigan’s Mislabeled Gross Receipts Tax

Michael Mcintyre
Michael J. McIntyre and Richard D. Pomp Abstract: On January 1, 2008, the State of Michigan implemented a new tax, labeled a modified gross receipts tax (MGRT). The label is misleading. The tax is not on gross receipts but rather on gross receipts reduced by "purchases from other firms," defined generally to include inventory purchased during the taxable year, capital purchases, and material and supplies. In some...

Reforming the Taxation of Derivatives – An Overview

Alex Raskolnikov
This brief essay outlines three benchmarks for evaluating alternative ways of taxing capital income, summarizes anticipatory, retroactive, and accrual based proposals for reforming the taxation of derivatives, and offers guidelines for evaluating more limited reforms. It is intended as an introduction to key concepts, tensions, and ideas for reforming the taxation of financial instruments. Derivatives (or financial...

The Meaning of Enterprise, Business, and Business Profits Under Tax Treaties and Domestic Tax Law (forthcoming, 2011)

Allison Christians
Written by: Allison Christians and Yariv Brauner[*] PART I. THE MEANING OF “ENTERPRISE” AND “BUSINESS” IN DOMESTIC NON-TAX LAW The terms ―business‖ and ―enterprise‖ are very widely used in United States legislation[1] Given the prevalence of the terms – business and enterprise, an exhaustive survey of their use in non-tax legislation in the United States is beyond the scope of this report....

Case Study Research and International Tax Theory

Allison Christians
Abstract Over the last ten years, legal scholars have begun to use what they describe as “case studies” in an effort to develop better theories about how governments can or should impose taxation on international activities. The attributes and function of case studies, while well-studied and documented in other disciplines, has not been explored in tax law scholarship. This Article explores case study research...

Employee Stock Options, Corporate Taxes and Debt Policy

John Graham
Written by: John R. Graham, Mark H. Lang and Douglas A. Shackelford Abstract: We find that employee stock option deductions lead to large aggregate tax savings for Nasdaq 100 and S&P 100 firms and also affect corporate marginal tax rates. For Nasdaq firms, including the effect of options reduces the estimated median marginal tax rate from 31 percent to 5 percent. For S&P firms, in contrast, option deductions...
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