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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...
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Minimizing the Harm Of State Fiscal Volatility

David Gamage
David Gamage and Jeremy Bearer-Friend This report's primary concern is how U.S. state governments should respond to the fiscal volatility created by their balanced budget constraints. Applying the principles of risk allocation theory to this recurring problem, we conclude that states should primarily adjust the rates of broad-based taxes as their economies cycle, rather than fluctuating public spending. More specifically,...
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Up or Down? Capital Income Taxation in the United States and the United Kingdom

Vito Polito
Abstract Empirical evidence suggests that the Effective Marginal Tax Rate (EMTR) on income from capital has increased considerably in both the United States and the United Kingdom over the period 1982-2005. This evidence contradicts the corporate tax literature which predicts that the EMTR should instead fall over time as a result of increasing international capital mobility and higher tax competition between governments....
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“Part Pay” Installment Agreements

Burton J. Haynes
The continuing hostility of the IRS bureaucracy toward offers in compromise, and the recent decision of the Congress to severely restrict the avail­ability and usefulness of bankruptcy, may combine to place more emphasis on installment agreements. But some taxpayers, particu­larly those with large tax debts involving multiple tax years, may find that they can't meet the requirements of the traditional installment agree­ment....
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A Brief Analysis of Governor Palin’s Tax Returns for 2006 and 2007

Bryan T. Camp
The release of an opinion letter by attorney Roger M. Olsen dated September 30, 2008, has stirred up the pot once again about the accuracy of Sarah and Todd Palin's 2006 and 2007 tax returns. Not only that, but Mr. Olsen's letter raises a couple of new issues. This paper focuses on five problems: three raised in the tax returns and two new ones raised by Mr. Olsen's letter. Here's a summary of the five problems and...
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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...
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Why Tax Incentives may be an ineffective tool to encouraging Investment? The role of Investment Climate

Stefan Van Parys
Stefan Van Parys,* Sebastian James Abstract: In this paper we first analyze theoretically how the investment climate affects the impact of the corporate tax rate on investment. We do so in a model where the tax revenues are used to improve the investment climate. We find that if the investment climate is very effective at enhancing the productivity of capital, capital can react positively to a rise...
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The Case for Tax-Free Internet Access: A Primer on the Internet Tax Freedom Act

Daniel Castro
If while watching the debate this year on renewing the Internet Tax Freedom Act, you experience dèja vu, you are not alone. We are hearing the same arguments and the same debate that we hear every time the Act comes up for renewal. Neither the facts nor the arguments have changed. The only question that remains is how much the views of Congress have changed. In 1998 Congress recognized that unnecessary and excessive...
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Global Trends and Constraints on Tax Policy in the Least Developed Countries

Allison Christians
Through decades of tax reform and cross-border collaboration, the world’s wealthiest countries have adopted domestic tax policy norms that meet their mutually beneficial interests. But these norms have introduced rigorous change and increasingly rigid parameters for tax policy in the world’s poorest countries. While much scholarly attention is devoted to identifying tax strategies that poor countries could or should...
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The Mysteries of Erroneous Refunds

Bryan T. Camp
I love my yearly tax refund. I know I'm not supposed to, but I do. Theorists argue that my refund represents an interest-free loan to the government and I am supposed to resent that for reasons grounded in the obsessive individualism of our culture. But even accepting the argument's premise, the value to me of that yearly manifestation of my forced savings outweighs the value of the interest I would theoretically earn...
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