User banner image
User avatar
  • Michael Mcintyre

Posts

The Deduction of Interest Payments in an Ideal Tax on Realized Business Profits

Abstract: The realization rule, which allows taxpayers to defer tax on certain accrued gains and prevents taxpayers from deducting certain unrealized losses, had a deduction...

Thoughts on the Future Of the State Corporate Income Tax

Several commentators recently have suggested that the state corporate income tax is dead, or nearly so, and hardly worth keeping. Writing in these pages, Kirk...

U.S. Taxation of Foreign Corporations in the Digital Age

Contents I. INTRODUCTION II. U.S. TAXATION OF THE BUSINESS PROFITS OF FOREIGN CORPORATIONS A. Overview B. Taxation of effectively connected income 1. Allowable deductions 2....

A Policy Analysis Of Michigan’s Mislabeled Gross Receipts Tax

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...

Comments on the OECD Proposal for Secret and Mandatory Arbitration of International Tax Disputes

The OECD has proposed amendments to its Model Tax Convention and Commentary that would establish a system for the mandatory arbitration of tax disputes between...

United Nations Code of Conduct on Cooperation in Combating International Tax Evasion

Abstract: Stopping international tax evasion and abusive tax avoidance is an exceedingly difficult task unless countries act together in a cooperative manner. The League of...
Skip to toolbar