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The Unhappy Marriage of Law and Equity in Joint Return Liability

Bryan T. Camp
It is no accident that Justice Holmes penned those words in a tax case. Of all the corners in all the laws governing citizen interaction with government, tax laws contain some of the squarest. Today’s column discusses what happens when Congress attempts to smooth out the sharp corners of the tax code with notions of equity, but does so with an inadequate understanding of, or appreciation for, the problems of tax administration....
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The Rise of the OECD as Informal; World Tax Organization; Through National Responses to E-commerce Tax Challenges

Arthur J. Cockfield
ABSTRACT This paper assesses national and international responses to tax challenges presented by cross-border electronic commerce. Ten years after these challenges were first identified, a survey of national government reactions shows that many countries have not passed any significant tax legislation or administrative guidance with respect to the taxation of global e-commerce. This lack of action at the national level...
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Negotiating Installment Agreements with the IRS Collection Division 

Burton J. Haynes
Written for the Maryland Society of Accountants One of the tasks most frequently faced in representing clients before the IRS Collection Division is negotiating an "installment agreement" -- an arrangement under which the taxpayer makes monthly payments against the outstanding tax debt, free of the threat of levy and distraint action. Despite the Service's imposition of a system of miserly national and local expense...
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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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The Section 734(b) Basis Adjustment Needs Repair

Howard Abrams
The partnership tax provisions – Subchapter K of the Internal Revenue Code – work pretty well. And they have a difficult job to do because they must provide a reasonable mechanism for taxing arrangements between parties that can be far from off-the-rack. It should not be difficult to figure out how to tax two individuals who contribute equal amounts of cash to start a joint business in which each will own a one-half...
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Dealing with tax debts in bankruptcy after the BAPCPA

Burton J. Haynes
The intended beneficiaries of the humorously titled "Bankruptcy Abuse Prevention and Consumer Protection Act of 2005" (BAPCPA) were the big banks and credit card companies -- lobbying pays. The new law also helps those with alimony and child support awards. But a third winner was your friendly, neighborhood tax collector. In general, the BAPCPA makes bankruptcies more cumbersome and expensive. But it also exempts certain...
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Can Redistributive State Taxes Reduce Inequality?

Andrew Leigh
ABSTRACT Do income taxes levied at a state or regional level affect the after-tax distribution of income? Or do workers merely move between regions, causing pre-tax wages to adjust? This question is relevant both in across states in the United States, and across countries within the European Union. Using the full income tax parameters for all US states from 1977-2002, I create a “simulated tax redistribution index”,...
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The Costs of Restrictive Trade Policies in the Presence of Factor Tax Distortions

Ian Parry
Abstract This paper uses a numerical general equilibrium model to examine the quantitative importance of pre-existing factor tax distortions for the welfare effects of tariffs and import quotas. The presence of preexisting taxes can greatly raise the costs of these policies, possibly by over several hundred percent. For a tariff much of this extra cost can be offset if tariff revenues are used to reduce distortionary...
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Taxation of the Really Big House

Calvin Johnson
A. Overview Serious long-term tax reform will need to limit the considerable tax advantages now available in owning the very largest houses and other personal-use properties. The primary return from the investment in residences and similar property is the rental value of the personal use of the house, which is always tax exempt. If the property appreciates, the gain from a principal residence is usually tax exempt....

The International Income Taxation of Portfolio Debt in the Presence of Bi-directional Capital Flows

Ewen Mccann
Written by : Ewen McCann and Tim Edgar Abstract - A country’s net flow of capital consists of simultaneously occurring imports and exports. Because a tax on the income from capital imports affects the quantity of capital exports and vice versa, tax policies toward inbound and outbound capital should be jointly formulated in order to avoid distortion of these bi-directional flows. For a small open economy, welfare-...
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