Profile photo of Bradley T. Borden

Tax Opinions in TIC Offerings and Reverse TIC Exchanges

Bradley T. Borden
Co-author: Todd D. Keator[*] TABLE OF CONTENTS I.INTRODUCTION II.DEVIATIONS FROM THE REVENUE PROCEDURE A.Common Deviations 1.Deemed Consent 3.Investor Loans 4.Sponsor Guarantees 5.Sponsor Bridge Loans B.Significant Deviations 1.Multiple Properties 2.Non-Pro Rata Debt 3.Construction Activities 4.Sponsor-Retained Interests III.REVERSE EXCHANGES INVOLVING TIC INTERESTs A.Securities Issues B.Contractual...
Profile photo of Richard Ainsworth

Transfer Pricing in VAT/GST vs. Direct Taxation: A Paper On The Topic Of Relations Between Associated Companies

Richard Ainsworth
Two caveats open this paper, one dealing with the scope of analysis, the other with the results we are expecting. First, the scope of this inquiry needs to be broadened. Even though the topic asks that we limit ourselves to VAT/GST and direct taxes, in most jurisdictions there are three (not two) spheres of transfer pricing analysis - income tax, customs and VAT/GST. Although they share policy objectives, terminology...
Profile photo of Edward Mccaffery

The Missing Links in Tax Reform

Edward Mccaffery
A funny thing happened on the way to fundamental tax reform: Nothing. Just a few short years ago, it looked as if we might have another great American tax revolt, akin to the one that started this country over two hundred years ago. Ronald Reagan had gotten the modern bandwagon started, first in California in the 1970s and later, from the White House, in the 1980s.[1] Politicians—like football coaches, investment...
Profile photo of John Graham

Employee Stock Options and Taxes

John Graham
Doug Shackelford
Courtney Edwards John R. Graham Mark H. Lang Doug Shackelford Abstract: In this paper, we investigate the effect of stock options on the tax position of the firm. We argue that option tax deductions can significantly affect a firm’s marginal tax rate and that the effect is masked by current financial reporting rules. We present an approach for factoring in option deductions in assessing a firm’s tax...
Profile photo of Allison Christians

Fair Taxation as a Basic Human Right

Allison Christians
ABSTRACT This symposium issue explores the limits and possibilities of law and legal institutions in redressing poverty and economic inequality. The following essay approaches the question by considering the ways in which domestic tax policy interacts with internationally-recognized human rights. I suggest that focusing on human rights discourse provides a needed vocabulary for addressing the global impact of domestic...
Profile photo of Chris Edwards

Fiscal Policy Report Card on America’s Governors: 2010

Chris Edwards
Executive Summary State governments have had to make tough budget choices in recent years. Tax revenues have stagnated as a result of the poor economy, and that has prompted governors to take a variety of fiscal actions to close large budget gaps. Some governors have cut spending to balance their budgets, while others have pursued large tax increases. That is the backdrop to this 10th biennial fis- cal report card...
Profile photo of Anthony Infanti

Prying Open The Closet Door: Doma And Tax Treaties

Anthony Infanti
I. INTRODUCTION In the wake of the events surrounding President Bush's endorsement of a constitutional ban on same-sex marriage,[2] a conservative, “pro-family“ organization[3] wrote the Commissioner of the Internal Revenue Service (IRS) earlier this year to alert him about “a potential fraudulent tax scheme.“[4] The organization was alarmed by “rebellious state and local officials reportedly permitting...
Profile photo of Calvin Johnson

Tax on Insurance Buildup

Calvin Johnson
Andrew Pike Eric A. Lustig Life insurance contracts often combine a savings or investment element with pure insurance protection that covers the risk of death during the year. Current law will tax the buildup in the value of a ‘‘life insurance contract’’ only if the policy is surrendered for its cash value during life. If the contract stays within the limits of a qualified insurance contract, the investment...
Profile photo of Arthur J. Cockfield

Introduction: The Last Battleground of Globalization

Arthur J. Cockfield
1.0 The Battle for International Investments The topic of globalization and tax is an ancient one. Writings in the area date back at least 2,500 years to the work of Herodotus, the ancient Greek scholar who coined the term 'history.'[1] In The Histories, Herodotus tells us of an era when ancient peoples came increasingly in contact with one another through cross-border trade and investment as well as warfare. He was...
Profile photo of Jerry Taylor

Don’t Increase Federal Gasoline Taxes; Abolish Them

Jerry Taylor
Written by: Jerry Taylor and Peter Van Doren Executive Summary Many experts believe that gasoline taxes should be increased for a variety of reasons. Their arguments are unpersuasive. Oil is not disappearing, and when it becomes more expensive, market agents will substitute away from gasoline to save money. The link between oil price shocks and recessions, although real in the 1970s, has been much more benign since...
- Enter Your Location -
- or -
Skip to toolbar