CAPITAL
The International Income Taxation of Portfolio Debt in the Presence of Bi-directional Capital Flows
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-...
A New Understanding of Tax
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”...
Canada-U.S. Free Trade and Pressures for Tax Coordination
The economies of the United States and Canada are closely linked-trade between the two countries is substantial, their capital markets are highly integrated, and even movement of individual workers between the two countries is non eligible. The U.S. and Canada have now agreed to eliminate all remaining tariff barriers between the two countries during the next few years. To what degree does this increasing economic integration...
Omnibus Capitalization Proposals
This shelf project proposal covers several expenditures that are allowed as expenses as soon as they are incurred under current law but should be treated as capital expenditures. Given the treatment of debt financing, capitalization is needed to prevent negative tax or subsidy for investments, many with dubious merit. The expensing subsidy allows projects to go forward that would lose money in the absence of tax. Absence...
Don’t Let Capital Accounts Go Negative
The proposal would prevent negative capital accounts as a remedy to prevent tax shelters. It would suspend deductions that would otherwise result in the taxpayer’s adjusted basis being lower than the outstanding debt. When capital accounts are negative, the transaction is a tax shelter in which tax is negative, that is, tax increases the pretax return. Limiting deductions to prevent negative capital accounts will prevent...
Innovation and Capital Gains Tax Policy — NYU School of Law
Innovation and Capital Gains Tax Policy -- NYU School of Law nyu,law,legal,education,founders,stock,capital,gains,policy, Author: nyuschooloflaw