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Key practical issues to eliminate double taxation of business income

Igor Mauler Santiago
Fernando Daniel de Moura FonsecaPost-graduate degree in Tax Law from Fundação Getúlio Vargas. Accountant. Lawyer. Updated version of the Brazilian national report presented to the 65th Congress of the International Fiscal Association (Paris, 2011). 1. INTRODUCTION The issues related to international double taxation and to the methods of preventing it necessarily relate to the intensification of economic relations...
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Impose Capital Gain Tax on Like-Kind Exchanges

Calvin Johnson
Current law allows a taxpayer to avoid taxation of gain on a disposition of real estate to the extent the taxpayer is willing to acquire other real estate as a replacement. The proposal would repeal section 1031 regarding gain and require an exchange broker to file an information return showing the amount realized by the taxpayer. Valuation is not a problem when the purchaser gives the cash price to an intermediary hired...
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Tax Shelters and Corporate Debt Policy

John Graham
Alan L. Tucker
John R. Graham Alan L. Abstract: We gather a unique sample of 44 tax shelter cases to investigate the magnitude of tax shelter activity and whether participating in a shelter is related to corporate debt policy. The average deduction produced by the shelters in our sample is very large, equaling approximately nine percent of asset value. These deductions are more than three times as large as interest deductions...
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UBIT to the Defense! ESOPs and Government Entities

Calvin Johnson
Calvin H. Johnson Ellen P. Aprill The unrelated trade or unrelated business income tax imposes tax on the unrelated business income of tax exempt organizations, including charities and pension plans. The general principle is that tax is imposed on business income no matter what its use or destination.UBIT defends the tax base by preventing the shift of business assets from taxable corporations to exempt entities....
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The Effects of the Length of the Tax-loss Carryback Period on Tax Receipts and Corporate Marginal Tax Rates

John Graham
Written by: John R. Graham and Hyunseob Kim Abstract We investigate how the length of the net operating loss carryback period affects corporate liquidity and marginal tax rates. We estimate that extending the carryback period from two to five years, as recently proposed in President Obama’s budget blueprint, would provide $19 ($34) billion of additional liquidity to the corporate sector for 2008 (2009). Our calculations...
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A New Understanding of Tax

Edward Mccaffery
Written by: Edward J. McCaffery I. INTRODUCTION A. Loomings Perhaps we should blame it all on Mill. A great deal and possibly all of the mind-numbing complexity of America’s largest and least popular tax follows from the decision to have a progressive personal income tax[2] Proponents wanted an individual income tax notwithstanding — indeed, in large part because of — such a tax’s “double taxation”...
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Pennsylvania’s Sales and Use Tax: has nearly $1 Billion been “zapped” away in Fraud?

Richard Ainsworth
The Sales and Use Tax is an essential part of Pennsylvania's revenue profile. Not only is it the State's second largest revenue source,[1] it has historically played a critical role in reducing the volatility of Pennsylvania's overall tax collections.[2] The sales tax is also critical to the city of Philadelphia,[3] and Allegheny County.[4] During the current economic downturn both the revenue and structural attributes...
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Considering Tax Expenditures In State Budget Deliberations

Bradley T. Borden
I. Introduction I am going to speak generally about three components of state public finance: first, tax revenue; second, government expenditures; and third, the allocation of the tax burden. I will illustrate how tax expenditures, such as sales-tax exemptions and other preferential laws, affect each component of public finance. In all of this, we must remember that budget deliberations should focus on keeping...
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Informational Hearing on the Tax Recommendations of the Commission on the 21st Century Economy

David Gamage
Mr. Chairman and Members of the Committee, it is my great pleasure to appear before you to discuss California's tax system. I would like to emphasize three points in my remarks: First, please do not throw out the baby with the bathwater! The Commission's report contains a number of sound, non-controversial, proposals that should be enacted without delay. Second, bi-partisan tax reform proposals should start with...
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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...
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