Stanley Surrey (1910-1984) was arguably the most important tax scholar of his generation. Surrey was a rare combination of an academic (Berkeley and Harvard law schools, 1947-1961 and 1969-1981) and a government official (Tax Legislative Counsel, 1942-1947; Assistant Secretary for Tax Policy, 1961-1969). Today he is mostly remembered for inventing the concept of tax expenditures and the tax expenditure budget. This paper will argue that while Surrey was influential in shaping domestic tax policy for a generation and had an impact after his death on the Tax Reform Act of 1986, his longest lasting contributions were in shaping the international tax regime, since the concept of the single tax principle that shapes contemporary international tax reform efforts can be traced directly to his writing and activities both in academia and in the government.
{"title":"Stanley Surrey, the Code and the Regime","authors":"R. Avi-Yonah, Nir Fishbien","doi":"10.2139/SSRN.3414965","DOIUrl":"https://doi.org/10.2139/SSRN.3414965","url":null,"abstract":"Stanley Surrey (1910-1984) was arguably the most important tax scholar of his generation. Surrey was a rare combination of an academic (Berkeley and Harvard law schools, 1947-1961 and 1969-1981) and a government official (Tax Legislative Counsel, 1942-1947; Assistant Secretary for Tax Policy, 1961-1969). Today he is mostly remembered for inventing the concept of tax expenditures and the tax expenditure budget. This paper will argue that while Surrey was influential in shaping domestic tax policy for a generation and had an impact after his death on the Tax Reform Act of 1986, his longest lasting contributions were in shaping the international tax regime, since the concept of the single tax principle that shapes contemporary international tax reform efforts can be traced directly to his writing and activities both in academia and in the government.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"2019 38","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-07-04","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"120848954","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In this article, Kadet and Koontz discuss certain issues that must be considered when a multinational analyzes whether it should transition certain operations conducted within a CFC (along with the associated income) into a domestic group member so as to achieve an FDII-qualifying structure. In doing so, there will likely be a need to move some key income-earning operations and functions to the United States to assure that the FDII foreign branch rule is not violated. Where a group has previously implemented a profit shifting structure that obfuscates where income is generated, there may be few or no operations or functions that require relocation to the United States. In such a case, the transition may highlight a tax exposure to unreported effectively connected income in pretransition years. The article notes Qualcomm's disclosed transition as a possible example of this.
{"title":"Transitioning From GILTI to FDII? Foreign Branch Income Issues","authors":"Jeffery M. Kadet, David L. Koontz","doi":"10.2139/SSRN.3428540","DOIUrl":"https://doi.org/10.2139/SSRN.3428540","url":null,"abstract":"In this article, Kadet and Koontz discuss certain issues that must be considered when a multinational analyzes whether it should transition certain operations conducted within a CFC (along with the associated income) into a domestic group member so as to achieve an FDII-qualifying structure. In doing so, there will likely be a need to move some key income-earning operations and functions to the United States to assure that the FDII foreign branch rule is not violated. \u0000 \u0000Where a group has previously implemented a profit shifting structure that obfuscates where income is generated, there may be few or no operations or functions that require relocation to the United States. In such a case, the transition may highlight a tax exposure to unreported effectively connected income in pretransition years. The article notes Qualcomm's disclosed transition as a possible example of this.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131008337","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Spanish Abstract: En no pocos CDI los Estados de la región iberoamericana tratan de potenciar el gravamen en fuente en lo que a rentas generadas por la industria del seguro se refiere, con resultados dispares. Este trabajo demuestra que la opción mayoritaria consistente en implementar cláusulas de seguro que amplían la definición de EP es inoperante para lograr el objetivo de aumentar la potestad tributaria en fuente, ya que la atribución de beneficios a estos EP será irrisoria. Si este es el resultado que se pretende lograr, la mejor opción pasa por incluir cláusulas en el contexto del artículo referido a rentas empresariales que habiliten el gravamen en fuente de las primas de seguro negociadas en ese Estado.
English Abstract: In many DTCs, the States of the Ibero-American region are trying to strengthen the taxation at source of income generated by the insurance industry, with mixed results. This work shows that the majority option, consisting of implementing insurance clauses that broaden the definition of PE is inoperative to achieve the objective of increasing tax authority at source, since the attribution of benefits to these PE will be derisory. If this is the result to be achieved, the best option is to include clauses in the context of the article referring to business income that enable the taxation at source of insurance premiums negotiated in that State.
{"title":"La atribución de beneficios a establecimientos permanentes de seguros en la red iberoamericana de convenios para evitar la doble imposición (The Attribution of Profits to Insurance Permanent Establishments in the Ibero-American Tax Treaty Network)","authors":"A. Navarro","doi":"10.2307/j.ctv1k03qpv.8","DOIUrl":"https://doi.org/10.2307/j.ctv1k03qpv.8","url":null,"abstract":"<b>Spanish Abstract:</b> En no pocos CDI los Estados de la región iberoamericana tratan de potenciar el gravamen en fuente en lo que a rentas generadas por la industria del seguro se refiere, con resultados dispares. Este trabajo demuestra que la opción mayoritaria consistente en implementar cláusulas de seguro que amplían la definición de EP es inoperante para lograr el objetivo de aumentar la potestad tributaria en fuente, ya que la atribución de beneficios a estos EP será irrisoria. Si este es el resultado que se pretende lograr, la mejor opción pasa por incluir cláusulas en el contexto del artículo referido a rentas empresariales que habiliten el gravamen en fuente de las primas de seguro negociadas en ese Estado.<br><br><b>English Abstract:</b> In many DTCs, the States of the Ibero-American region are trying to strengthen the taxation at source of income generated by the insurance industry, with mixed results. This work shows that the majority option, consisting of implementing insurance clauses that broaden the definition of PE is inoperative to achieve the objective of increasing tax authority at source, since the attribution of benefits to these PE will be derisory. If this is the result to be achieved, the best option is to include clauses in the context of the article referring to business income that enable the taxation at source of insurance premiums negotiated in that State.<br>","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"327 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-06-22","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116644341","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
We apply an unsupervised machine learning algorithm to revisit legislative lags of U.S. tax reforms and show that at least two lags have been longer than previously identified. Our approach offers an alternative way to approximate U.S. tax foresight, given that the relationship between tax exempt municipal bonds and taxable U.S. Treasury securities has broken down in 2007.
{"title":"Revisiting Legislative Lags of U.S. Tax Reforms","authors":"P. Adämmer, T. Dybowski","doi":"10.2139/ssrn.3075049","DOIUrl":"https://doi.org/10.2139/ssrn.3075049","url":null,"abstract":"We apply an unsupervised machine learning algorithm to revisit legislative lags of U.S. tax reforms and show that at least two lags have been longer than previously identified. Our approach offers an alternative way to approximate U.S. tax foresight, given that the relationship between tax exempt municipal bonds and taxable U.S. Treasury securities has broken down in 2007.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"35 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-05-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"124370332","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Part I: Billionaire Taxes, https://ssrn.com/abstract=3326615. Part III: After Paying Ultra-High Net Worth Wealth Taxes, How Much Would Billionaires Have Left to Live on?, https://ssrn.com/abstract=3340925. Key Takeaways: - Innovation is the product of teamwork. - Engineers and scientists play a critical role. - Scientific research is insufficiently rewarded financially. - Taxes can boost innovation by funding human capital investment and basic research. - The amount of investment is important – who owns financial assets is not. In formulating taxation and public investment policies, we should carefully consider data and the peer reviewed literature. Claims that we can drive more innovation and growth through a higher concentration of resources in the hands of a small number of billionaires — while providing fewer resources to middle and upper middle-class knowledge workers — are not empirically supported.
{"title":"Taxes, Spending, and Innovation","authors":"M. Simkovic","doi":"10.2139/SSRN.3335386","DOIUrl":"https://doi.org/10.2139/SSRN.3335386","url":null,"abstract":"Part I: Billionaire Taxes, https://ssrn.com/abstract=3326615. \u0000Part III: After Paying Ultra-High Net Worth Wealth Taxes, How Much Would Billionaires Have Left to Live on?, https://ssrn.com/abstract=3340925. \u0000 \u0000Key Takeaways: \u0000 \u0000- Innovation is the product of teamwork. \u0000- Engineers and scientists play a critical role. \u0000- Scientific research is insufficiently rewarded financially. \u0000- Taxes can boost innovation by funding human capital investment and basic research. \u0000- The amount of investment is important – who owns financial assets is not. \u0000 \u0000In formulating taxation and public investment policies, we should carefully consider data and the peer reviewed literature. Claims that we can drive more innovation and growth through a higher concentration of resources in the hands of a small number of billionaires — while providing fewer resources to middle and upper middle-class knowledge workers — are not empirically supported.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"37 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-05-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"125442578","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Through this article we want to present the role of the fiscal administrative act in the Romanian tax system. Thus, we will define the fiscal administrative act and other institutions specific to the Romanian tax system, such as the administration of fiscal burdens by the tax authorities or the procedure for communicating the fiscal administrative act. Also, we will present the legal effects produced by this act, its traits and its conditions of form and substance, as well as its role in the Romanian tax system.
{"title":"The Role of the Fiscal Administrative Act in the Romanian Tax System","authors":"Alice Maria Cristina Zdanovschi","doi":"10.2139/SSRN.3388078","DOIUrl":"https://doi.org/10.2139/SSRN.3388078","url":null,"abstract":"Through this article we want to present the role of the fiscal administrative act in the Romanian tax system. Thus, we will define the fiscal administrative act and other institutions specific to the Romanian tax system, such as the administration of fiscal burdens by the tax authorities or the procedure for communicating the fiscal administrative act. Also, we will present the legal effects produced by this act, its traits and its conditions of form and substance, as well as its role in the Romanian tax system.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"35 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-04-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114617171","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2019-04-23DOI: 10.17159/1727-3781/2019/V22I0A5705
F. Moosa
Sections 45 and 63 of the Tax Administration Act 28 of 2011 (TAA) confer drastic information gathering powers on officials of the South African Revenue Service (SARS). On the one hand, section 45 permits warrantless routine (non-targeted) and non-routine (targeted) inspections by a SARS official in respect of records, books of accounts and documents found at premises where a taxpayer is reasonably believed to be conducting a trade or enterprise. The purpose of such inspection is to determine whether there has been compliance with specific obligations by the taxpayer. Section 63, on the other hand, permits, on the grounds of urgency and expediency in exceptional circumstances only, warrantless non-routine (targeted) searches by a senior SARS official of a taxpayer and of third parties associated with a taxpayer, as well as searches of a taxpayer's premises and those of third parties. In addition, section 63 permits the seizure of relevant material found at premises searched. All searches and seizures must occur for the purposes of the efficient and effective administration of tax Acts generally. A comparative analysis of sections 45 and 63 of the TAA reveals the existence of key differences in the substance and practical operation of their provisions. This article distils these differences through an in-depth discussion of the nature and extent of the powers of inspection and search conferred by these provisions, as well as by conceptualising the terms “inspection” and “search” for the purposes of sections 45 and 63 respectively.
{"title":"Analysing and Comparing Warrantless Tax Inspections and Searches","authors":"F. Moosa","doi":"10.17159/1727-3781/2019/V22I0A5705","DOIUrl":"https://doi.org/10.17159/1727-3781/2019/V22I0A5705","url":null,"abstract":"Sections 45 and 63 of the Tax Administration Act 28 of 2011 (TAA) confer drastic information gathering powers on officials of the South African Revenue Service (SARS). On the one hand, section 45 permits warrantless routine (non-targeted) and non-routine (targeted) inspections by a SARS official in respect of records, books of accounts and documents found at premises where a taxpayer is reasonably believed to be conducting a trade or enterprise. The purpose of such inspection is to determine whether there has been compliance with specific obligations by the taxpayer. Section 63, on the other hand, permits, on the grounds of urgency and expediency in exceptional circumstances only, warrantless non-routine (targeted) searches by a senior SARS official of a taxpayer and of third parties associated with a taxpayer, as well as searches of a taxpayer's premises and those of third parties. In addition, section 63 permits the seizure of relevant material found at premises searched. All searches and seizures must occur for the purposes of the efficient and effective administration of tax Acts generally. A comparative analysis of sections 45 and 63 of the TAA reveals the existence of key differences in the substance and practical operation of their provisions. This article distils these differences through an in-depth discussion of the nature and extent of the powers of inspection and search conferred by these provisions, as well as by conceptualising the terms “inspection” and “search” for the purposes of sections 45 and 63 respectively. \u0000 \u0000 ","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"37 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-04-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"128690904","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The concept of the permanent establishment is fast approaching its hundredth year. When it was firstly shaped, it was destined to serve specific policies by tackling certain inconveniences. In order to achieve that, the economic climate (the business status quo) had to be taken into account, so as for the given regulation to be adjusted. All the above happened and the result was brilliant. Though, things have not remained the same throughout this century; after all, should this have happened, it would have been alarming. It is oxymoron - but also true - that nowadays, a permanent establishment does neither need to be permanent, nor even an establishment. Arguably, a sceptical approach, indicatively focused on the condition of the permanence and the fixedness for establishing a PE, through its history, may demonstrate that the time passage has led to a dysfunction. A new nexus is imperatively needed. This article ends with a thought-provoking question, regarding the need of a new method for the calculation of tax liability when a permanent establishment is ascertained; given that the policy - which dictates the measures deployed - cannot be but closely related to the problems it aspirates to solve. Having said that, not only have the problems changed, but they have also proliferated; so maybe the policy (and as a consequence the fundaments of the measures deployed) must also be differentiated.
{"title":"The Concept of the (Neither) Permanent (nor an) Establishment and the (Destination Favourable) Attribution of Profits","authors":"Giannis Psarakis","doi":"10.2139/ssrn.3362752","DOIUrl":"https://doi.org/10.2139/ssrn.3362752","url":null,"abstract":"The concept of the permanent establishment is fast approaching its hundredth year. When it was firstly shaped, it was destined to serve specific policies by tackling certain inconveniences. In order to achieve that, the economic climate (the business status quo) had to be taken into account, so as for the given regulation to be adjusted. All the above happened and the result was brilliant. Though, things have not remained the same throughout this century; after all, should this have happened, it would have been alarming. It is oxymoron - but also true - that nowadays, a permanent establishment does neither need to be permanent, nor even an establishment. Arguably, a sceptical approach, indicatively focused on the condition of the permanence and the fixedness for establishing a PE, through its history, may demonstrate that the time passage has led to a dysfunction. A new nexus is imperatively needed. This article ends with a thought-provoking question, regarding the need of a new method for the calculation of tax liability when a permanent establishment is ascertained; given that the policy - which dictates the measures deployed - cannot be but closely related to the problems it aspirates to solve. Having said that, not only have the problems changed, but they have also proliferated; so maybe the policy (and as a consequence the fundaments of the measures deployed) must also be differentiated.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"120 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-03-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"124504569","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
While there is considerable uncertainty regarding the US Tax Cut and Jobs Act’s (TCJA) economic and fiscal impacts, one thing is certain – the significant corporate tax competitiveness advantage that Canada enjoyed over the US for years has disappeared. This Commentary explores some major TCJA measures as they relate to corporations, examines their implications for Canadian business, evaluates Ottawa’s response in the Fall Economic Statement and discusses what is required going forward. The TCJA impact on real domestic investment in Canada is complicated, with competing effects. The TJCA will likely have a net negative effect on domestic and US foreign investment in Canada, moderated in the long-run by the international nature of capital markets. Still, concerns remain about income shifting due to the statutory rate reductions in the US. Our review of the academic literature suggests the US tax-rate cut will result in Canadian affiliates of US companies shifting homeward 8 percent to 28 percent of their profits – a back-of-the-envelope calculation for sure, but nonetheless suggesting a potential significant impact on Canadian corporate tax revenues. The TCJA represents a long overdue sea change in US corporate taxation and, on balance, will have a positive impact on investment and productivity in that country. However, the reform is not anchored in sound tax principles and introduces undesirable distortions. Ottawa, in its 2018 Fall Economic Statement, duplicated in part some aspects of the US reforms in accelerated depreciation for new capital expenditures. While we think that this short-run response is reasonable in light of the fiscal constraints facing the government and the uncertainty regarding the impact of the TCJA, we do not think that the work is done. The US reform provides an opportunity to make a bold move toward a corporate tax system in Canada that is grounded in sound tax policy principles, is less distortionary, promotes economic growth and prosperity, and restores Canada’s tax competitiveness on a worldwide basis. A structured, principled approach to tax reform in Canada is preferable than an ad hoc response to US developments, which may turn out to be fragile in light of the American political climate and the point in the business cycle. We advocate for a corporate tax system based on the taxation of economic “rents.” A simple example of such a regime is a cash-flow tax, which would involve the immediate write-off of all capital expenditures coupled with the elimination of the debt-interest deduction. The basic idea is to replace the corporate income tax with a rent tax that taxes only the above-normal return on investment and is, therefore, neutral with respect to business investment and financing decisions. A cash-flow tax would reduce the business cost of capital investment by roughly 20 percent – offering a much greater boost to capital investment than alternative and fractional reforms such as temporary accelerated depreci
{"title":"Tax Policy Next to the Elephant: Business Tax Reform in the Wake of the US Tax Cuts and Jobs Act","authors":"K. Mckenzie, M. Smart","doi":"10.2139/ssrn.3352718","DOIUrl":"https://doi.org/10.2139/ssrn.3352718","url":null,"abstract":"While there is considerable uncertainty regarding the US Tax Cut and Jobs Act’s (TCJA) economic and fiscal impacts, one thing is certain – the significant corporate tax competitiveness advantage that Canada enjoyed over the US for years has disappeared. This Commentary explores some major TCJA measures as they relate to corporations, examines their implications for Canadian business, evaluates Ottawa’s response in the Fall Economic Statement and discusses what is required going forward. The TCJA impact on real domestic investment in Canada is complicated, with competing effects. The TJCA will likely have a net negative effect on domestic and US foreign investment in Canada, moderated in the long-run by the international nature of capital markets. Still, concerns remain about income shifting due to the statutory rate reductions in the US. Our review of the academic literature suggests the US tax-rate cut will result in Canadian affiliates of US companies shifting homeward 8 percent to 28 percent of their profits – a back-of-the-envelope calculation for sure, but nonetheless suggesting a potential significant impact on Canadian corporate tax revenues. The TCJA represents a long overdue sea change in US corporate taxation and, on balance, will have a positive impact on investment and productivity in that country. However, the reform is not anchored in sound tax principles and introduces undesirable distortions. Ottawa, in its 2018 Fall Economic Statement, duplicated in part some aspects of the US reforms in accelerated depreciation for new capital expenditures. While we think that this short-run response is reasonable in light of the fiscal constraints facing the government and the uncertainty regarding the impact of the TCJA, we do not think that the work is done. The US reform provides an opportunity to make a bold move toward a corporate tax system in Canada that is grounded in sound tax policy principles, is less distortionary, promotes economic growth and prosperity, and restores Canada’s tax competitiveness on a worldwide basis. A structured, principled approach to tax reform in Canada is preferable than an ad hoc response to US developments, which may turn out to be fragile in light of the American political climate and the point in the business cycle. We advocate for a corporate tax system based on the taxation of economic “rents.” A simple example of such a regime is a cash-flow tax, which would involve the immediate write-off of all capital expenditures coupled with the elimination of the debt-interest deduction. The basic idea is to replace the corporate income tax with a rent tax that taxes only the above-normal return on investment and is, therefore, neutral with respect to business investment and financing decisions. A cash-flow tax would reduce the business cost of capital investment by roughly 20 percent – offering a much greater boost to capital investment than alternative and fractional reforms such as temporary accelerated depreci","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"14 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-03-14","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"132565461","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article looks into China’s individual income tax framework, focusing on the exemption system and examining its problems in theory and in practice. Then it proposes a series of reforms intended to promote the fundamental tax principles both in the exemption system and in China’s individual taxation system more generally.
{"title":"China’s Individual Income Tax Exemption System: Problems and Proposals","authors":"Yue Dai","doi":"10.2139/ssrn.3396815","DOIUrl":"https://doi.org/10.2139/ssrn.3396815","url":null,"abstract":"This article looks into China’s individual income tax framework, focusing on the exemption system and examining its problems in theory and in practice. Then it proposes a series of reforms intended to promote the fundamental tax principles both in the exemption system and in China’s individual taxation system more generally.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"39 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-03-11","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130327609","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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