This paper identifies key tax design issues for how income tax law should treat litigation-related costs paid by defendants, such as attorney fees, court courts, and payments to settle claims or to satisfy judgments, fines or penalties. After discussing how US and German income tax law treat litigation-related costs, the paper identifies four important tax-design issues: (1) how to attribute litigation-related costs to any particular income-producing activity; (2) whether to treat liability insurer payments made on a defendant’s behalf as income to that defendant; (3) whether to coordinate the tax treatment of a payer’s damages payments with the tax treatment of those receipts to the payee; and (4) whether litigation-related costs should be treated as capital expenditures related to the right to receipts established or sought to be established by the litigation itself. In addition, the paper models how the tax-deductibility of liability-related costs might affect liability insurance demand and the insured taxpayer’s level of care. Finally, the paper shows how, under current law, private parties can enforce settlement agreements under which a defendant promises not to seek an allowable tax deduction for litigation-related costs. In so doing, this paper substantially extends and reorients tax theory on how an ideal income tax system could or should treat litigation-related costs
{"title":"Designing the Tax Treatment of Litigation-Related Costs","authors":"Sachin S. Pandya, S. Utz","doi":"10.5744/FTR.2018.0007","DOIUrl":"https://doi.org/10.5744/FTR.2018.0007","url":null,"abstract":"This paper identifies key tax design issues for how income tax law should treat litigation-related costs paid by defendants, such as attorney fees, court courts, and payments to settle claims or to satisfy judgments, fines or penalties. After discussing how US and German income tax law treat litigation-related costs, the paper identifies four important tax-design issues: (1) how to attribute litigation-related costs to any particular income-producing activity; (2) whether to treat liability insurer payments made on a defendant’s behalf as income to that defendant; (3) whether to coordinate the tax treatment of a payer’s damages payments with the tax treatment of those receipts to the payee; and (4) whether litigation-related costs should be treated as capital expenditures related to the right to receipts established or sought to be established by the litigation itself. In addition, the paper models how the tax-deductibility of liability-related costs might affect liability insurance demand and the insured taxpayer’s level of care. Finally, the paper shows how, under current law, private parties can enforce settlement agreements under which a defendant promises not to seek an allowable tax deduction for litigation-related costs. In so doing, this paper substantially extends and reorients tax theory on how an ideal income tax system could or should treat litigation-related costs","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"9 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-05-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"123456878","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}
What would you do if on January 13, 2016, you had won the $1.5 billion Powerball jackpot? The prize gives you the choice of a smaller lump sum now or the full jackpot parceled out for years to come. For the New York Times and numerous financial experts, the right choice is clear: take the money over time. While lump sums are nice, they are not worth a big discount when compared to “ultrasafe” income streams (like the Powerball annuity), especially in an “ultralow interest rate environment.”What everyone understands about Powerball seems to elude us when it comes to the United States’ largest corporate tax expenditure. “Accelerated depreciation” rules give taxpayers a lump sum deduction now, rather than the gradual deductions they would normally claim. Called tax law’s “standard method for combating recessions,” accelerated depreciation has become the most important tax policy affecting businesses because it is thought to be an effective if costly way to stimulate the economy, particularly during tough economic times.I argue, to the contrary, that accelerated depreciation debates ignore the lessons of Powerball. Like lottery payments, gradual depreciation deductions are highly certain, making them far more valuable than has been assumed. As a result, replacing them with accelerated depreciation is far less valuable than has been assumed. Further, the benefits of accelerated depreciation plummet during and following recession—precisely when these policies tend to be expanded. I illustrate these points with a numerical example exposing when real firms paid extra taxes (and the government collected extra revenue) as a result of the government’s purported stimulus program.
{"title":"Accelerating Depreciation in Recession","authors":"Rebecca N. Morrow","doi":"10.5744/ftr.2016.1008","DOIUrl":"https://doi.org/10.5744/ftr.2016.1008","url":null,"abstract":"What would you do if on January 13, 2016, you had won the $1.5 billion Powerball jackpot? The prize gives you the choice of a smaller lump sum now or the full jackpot parceled out for years to come. For the New York Times and numerous financial experts, the right choice is clear: take the money over time. While lump sums are nice, they are not worth a big discount when compared to “ultrasafe” income streams (like the Powerball annuity), especially in an “ultralow interest rate environment.”What everyone understands about Powerball seems to elude us when it comes to the United States’ largest corporate tax expenditure. “Accelerated depreciation” rules give taxpayers a lump sum deduction now, rather than the gradual deductions they would normally claim. Called tax law’s “standard method for combating recessions,” accelerated depreciation has become the most important tax policy affecting businesses because it is thought to be an effective if costly way to stimulate the economy, particularly during tough economic times.I argue, to the contrary, that accelerated depreciation debates ignore the lessons of Powerball. Like lottery payments, gradual depreciation deductions are highly certain, making them far more valuable than has been assumed. As a result, replacing them with accelerated depreciation is far less valuable than has been assumed. Further, the benefits of accelerated depreciation plummet during and following recession—precisely when these policies tend to be expanded. I illustrate these points with a numerical example exposing when real firms paid extra taxes (and the government collected extra revenue) as a result of the government’s purported stimulus program.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"5 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-05-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"126663600","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 : 2018-04-30DOI: 10.6092/ISSN.2036-3583/9155
Patrici Masbernat
The purpose of this paper is to research about the possibility to identify a legal dogma body in mining taxation and to show a certain disciplinary unity of Mining Tax Law, as a particular area of Tax Law with a strong link to Mining Law and Economic Law, among others characteristics. To do so, it explains specific problems, concepts, and categories that are usually dealt with by the law that regulate this industry. That is, use the method of legal doctrine in Comparative Law. This report is exploratory and does not pursue to present definitive or closed conclusions, because it is the first paper of a line of research that the authors have been working for some years. Given the extent allowed to this class of work, evidence of such disciplinary identity will be presented rather than adequately formulating a general theory of mining tax law.
{"title":"The Mining Tax Law in a Comparative Perspective","authors":"Patrici Masbernat","doi":"10.6092/ISSN.2036-3583/9155","DOIUrl":"https://doi.org/10.6092/ISSN.2036-3583/9155","url":null,"abstract":"The purpose of this paper is to research about the possibility to identify a legal dogma body in mining taxation and to show a certain disciplinary unity of Mining Tax Law, as a particular area of Tax Law with a strong link to Mining Law and Economic Law, among others characteristics. To do so, it explains specific problems, concepts, and categories that are usually dealt with by the law that regulate this industry. That is, use the method of legal doctrine in Comparative Law. This report is exploratory and does not pursue to present definitive or closed conclusions, because it is the first paper of a line of research that the authors have been working for some years. Given the extent allowed to this class of work, evidence of such disciplinary identity will be presented rather than adequately formulating a general theory of mining tax law.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"42 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-04-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115140240","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 double tax imposed on the earnings of C corporations results in significant economic inefficiencies because of its effect on the choice of entity for conducting a business. All other items being equal, the double tax distorts taxpayers’ choice of entity because it motivates taxpayers to favor flow-through entities when they otherwise would not. The reduction in the corporate and individual tax rates in the legislation popularly known as the Tax Cuts and Jobs Act of 2017 (the “2017 Tax Act”) has been in part justified on the grounds that the rate changes would help achieve parity between effective tax rates imposed on C corporations and on flow-through entities.
{"title":"The Impact of the 2017 Act's Tax Rate Changes on Choice of Entity","authors":"James R. Repetti","doi":"10.5744/FTR.2018.0011","DOIUrl":"https://doi.org/10.5744/FTR.2018.0011","url":null,"abstract":"The double tax imposed on the earnings of C corporations results in significant economic inefficiencies because of its effect on the choice of entity for conducting a business. All other items being equal, the double tax distorts taxpayers’ choice of entity because it motivates taxpayers to favor flow-through entities when they otherwise would not. The reduction in the corporate and individual tax rates in the legislation popularly known as the Tax Cuts and Jobs Act of 2017 (the “2017 Tax Act”) has been in part justified on the grounds that the rate changes would help achieve parity between effective tax rates imposed on C corporations and on flow-through entities.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"123 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-03-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"127051393","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 topic of redistribution between rich and poor countries opens a can of worms. This paper first inquires into what we mean by some of these words and second, considers the role of taxation in redistribution. It briefly considers the various modes of redistribution to address poverty and inequality, including the role of taxation, within a country before turning to consider modes of redistribution between rich and poor countries. The paper then turns to consider whether we are asking the right question. Should the question, really, be about redistribution between rich and poor people? In an increasingly global and digital era, how might we reconsider the role of taxation in achieving this? The paper briefly touches on state-based and cosmopolitan theories of international distributive justice, before considering whether we need to unpack the very concept of the country, nation-state, or government to achieve the transnational provision of public goods and redistribution between rich and poor.
{"title":"Redistribution between Rich and Poor Countries","authors":"M. Stewart","doi":"10.2139/ssrn.3140135","DOIUrl":"https://doi.org/10.2139/ssrn.3140135","url":null,"abstract":"The topic of redistribution between rich and poor countries opens a can of worms. This paper first inquires into what we mean by some of these words and second, considers the role of taxation in redistribution. It briefly considers the various modes of redistribution to address poverty and inequality, including the role of taxation, within a country before turning to consider modes of redistribution between rich and poor countries. The paper then turns to consider whether we are asking the right question. Should the question, really, be about redistribution between rich and poor people? In an increasingly global and digital era, how might we reconsider the role of taxation in achieving this? The paper briefly touches on state-based and cosmopolitan theories of international distributive justice, before considering whether we need to unpack the very concept of the country, nation-state, or government to achieve the transnational provision of public goods and redistribution between rich and poor.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"67 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121297170","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 undertakes a comparative analysis of doing business in the European Union’s Schengen Bloc vis-a-vis working in the Schengen Bloc. Through a critical review of what may constitute business activities vs. work in all 17 Schengen member states, the article establishes how international companies can minimize unintentional exposure to immigration noncompliance as well as possible tax liabilities. As the article observes, there is a general absence of a standard EU legal definition of ‘work’ vs. ‘business activities’ that international companies can apply when sending employees for business purposes to the Schengen Bloc. In the absence of specific criteria, the article outlines what characterizes business activities in 17 Schengen countries and then several international standards, which concerned parties can use a reference point. By examining various sources including EU, OECD and ILO frameworks, the article’s research indicates general terms of reference in distinguishing business activities from work, and how that distinction confers the need for a business visa or a work permit in the European Union’s Schengen Bloc.
{"title":"Not Just Business as Usual in the EU: A Comprehensive Analysis of Immigration and Tax Issues Related to Business Trips in 17 Schengen Countries","authors":"Marco Mazzeschi, Clayton E. Cartwright Jr","doi":"10.5430/IJBA.V9N2P46","DOIUrl":"https://doi.org/10.5430/IJBA.V9N2P46","url":null,"abstract":"This article undertakes a comparative analysis of doing business in the European Union’s Schengen Bloc vis-a-vis working in the Schengen Bloc. Through a critical review of what may constitute business activities vs. work in all 17 Schengen member states, the article establishes how international companies can minimize unintentional exposure to immigration noncompliance as well as possible tax liabilities. As the article observes, there is a general absence of a standard EU legal definition of ‘work’ vs. ‘business activities’ that international companies can apply when sending employees for business purposes to the Schengen Bloc. In the absence of specific criteria, the article outlines what characterizes business activities in 17 Schengen countries and then several international standards, which concerned parties can use a reference point. By examining various sources including EU, OECD and ILO frameworks, the article’s research indicates general terms of reference in distinguishing business activities from work, and how that distinction confers the need for a business visa or a work permit in the European Union’s Schengen Bloc.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"167 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-02-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122069656","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}
Why is regulation of charity so pervasive? Is regulation justifiable from a perspective of economic theory? How can it be squared with the fundamentally private—that is, non-governmental—nature of charitable firms? This chapter explores five major questions in the design and implementation of regimes for regulation of charity, with the analysis centered in transaction-cost economics. I first consider the bedrock issue of what, if anything, justifies the extensive modern role government regulation plays in the private nonprofit sector. In many respects the question is not particularly different for charitable firms than it is for commercial operations. Unlike many commercial firms, however, charities in many developed countries are subsidized by the state, and these subsidies offer additional reasons for public oversight. The second and third sections are closely related, and examine from different perspectives the extent to which regulation of charity need be provided by government, rather than by private auditors or other monitors. The second section reviews the alternative of "voluntary regulation" or "self-regulation." In the third section, I evaluate arguments about whether private parties should be granted the right to sue charitable organizations to enforce compliance with law or self-imposed governance standards. In both sections I conclude that, while active government monitoring is likely essential to any effective regime, there also are openings for important contributions from private oversight. The fourth section considers a recurring tension in public supervision of charities, namely: how can charities represent a diverse array of private views when closely supervised by a possibly unsympathetic government? Courts and scholars of charity law tend to favor minimalist, bright-line, and procedure-based rules for charity governance, on the theory that these approaches reduce the room for bureaucratic discretion. I argue, to the contrary, that other institutional design choices can strike a better balance between safeguarding public interests and minimizing damage to the charitable sector. Lastly, in the fifth section, I examine what little is known about charitable compliance with law. The section provides an overview of compliance theory and evidence in the context of commercial firms, as well as the limited evidence available for charity.
{"title":"Design and Implementation of a Charitable Regulation Regime","authors":"Brian Galle","doi":"10.2139/ssrn.3111907","DOIUrl":"https://doi.org/10.2139/ssrn.3111907","url":null,"abstract":"Why is regulation of charity so pervasive? Is regulation justifiable from a perspective of economic theory? How can it be squared with the fundamentally private—that is, non-governmental—nature of charitable firms? This chapter explores five major questions in the design and implementation of regimes for regulation of charity, with the analysis centered in transaction-cost economics. \u0000I first consider the bedrock issue of what, if anything, justifies the extensive modern role government regulation plays in the private nonprofit sector. In many respects the question is not particularly different for charitable firms than it is for commercial operations. Unlike many commercial firms, however, charities in many developed countries are subsidized by the state, and these subsidies offer additional reasons for public oversight. \u0000The second and third sections are closely related, and examine from different perspectives the extent to which regulation of charity need be provided by government, rather than by private auditors or other monitors. The second section reviews the alternative of \"voluntary regulation\" or \"self-regulation.\" In the third section, I evaluate arguments about whether private parties should be granted the right to sue charitable organizations to enforce compliance with law or self-imposed governance standards. In both sections I conclude that, while active government monitoring is likely essential to any effective regime, there also are openings for important contributions from private oversight. \u0000The fourth section considers a recurring tension in public supervision of charities, namely: how can charities represent a diverse array of private views when closely supervised by a possibly unsympathetic government? Courts and scholars of charity law tend to favor minimalist, bright-line, and procedure-based rules for charity governance, on the theory that these approaches reduce the room for bureaucratic discretion. I argue, to the contrary, that other institutional design choices can strike a better balance between safeguarding public interests and minimizing damage to the charitable sector. \u0000Lastly, in the fifth section, I examine what little is known about charitable compliance with law. The section provides an overview of compliance theory and evidence in the context of commercial firms, as well as the limited evidence available for charity.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":" 52","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-01-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"120829503","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}
Lily L. Batchelder, Elaine M. Maag, Chye-Ching Huang, E. Horton
During the presidential campaign, Donald Trump proposed three tax benefits for child care: a credit for low-income families, an above-the-line deduction, and tax-subsidized savings accounts. While these proposals laudably bring attention to the heavy burden that child care costs place on many low- and middle-income families, they are a case study in how not to reform child care policy. They are unduly complicated, arbitrarily exclude certain low-income families, deliver support well after child care payments are due, and provide the largest benefits to higher-income families who need the least help.
{"title":"Assessing President Trump's Child Care Proposals","authors":"Lily L. Batchelder, Elaine M. Maag, Chye-Ching Huang, E. Horton","doi":"10.2139/ssrn.3062318","DOIUrl":"https://doi.org/10.2139/ssrn.3062318","url":null,"abstract":"During the presidential campaign, Donald Trump proposed three tax benefits for child care: a credit for low-income families, an above-the-line deduction, and tax-subsidized savings accounts. While these proposals laudably bring attention to the heavy burden that child care costs place on many low- and middle-income families, they are a case study in how not to reform child care policy. They are unduly complicated, arbitrarily exclude certain low-income families, deliver support well after child care payments are due, and provide the largest benefits to higher-income families who need the least help.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"6 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-10-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"123812143","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 present paper addresses the most important issues regarding how are currently conducted the activities assigned to specialized institutions of the state, activities directed to identify any kind of thefts by taxpayers from the payment obligations to the consolidated state budget. The references found here are made mainly from normative perspective, taking account of the juridical norms applicable "on day". Also the strengths and weaknesses of the investigative activity in the field of taxation are indicated (fraud control, tax inspection, etc.), also with some solutions to improve the institutional framework (de lege ferenda proposals).
{"title":"Adapting the Legal Framework of the Financial-Fiscal Investigations to Current Requirement","authors":"I. Bostan","doi":"10.2139/ssrn.3059578","DOIUrl":"https://doi.org/10.2139/ssrn.3059578","url":null,"abstract":"The present paper addresses the most important issues regarding how are currently conducted the activities assigned to specialized institutions of the state, activities directed to identify any kind of thefts by taxpayers from the payment obligations to the consolidated state budget. The references found here are made mainly from normative perspective, taking account of the juridical norms applicable \"on day\". Also the strengths and weaknesses of the investigative activity in the field of taxation are indicated (fraud control, tax inspection, etc.), also with some solutions to improve the institutional framework (de lege ferenda proposals).","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"25 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-10-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"125442413","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 examines several elements of the case currently being advanced for reducing Australia’s corporate tax rate to 25%. In essence, the proposal is for an immediate, certain and widely dispersed revenue loss wagered in the hope of triggering a contingent and deferred response from a narrow target. The article revisits the history of this proposal and the development of the argument in the last two decades. It then queries some impressions embedded in the current debate — that the proposal is for a tax cut, that a 30% rate on commercial profit is actually paid (or meant to be paid) by most companies, that the imputation system will negate much of the cost of the lost revenue and that most foreign investors will benefit from a reduced corporate rate. The article concludes that, while the proposal may be sensible for other reasons, the case currently being made is unconvincing.
{"title":"The Unconvincing Case for 25%","authors":"G. Cooper","doi":"10.2139/SSRN.3059257","DOIUrl":"https://doi.org/10.2139/SSRN.3059257","url":null,"abstract":"This article examines several elements of the case currently being advanced for reducing Australia’s corporate tax rate to 25%. In essence, the proposal is for an immediate, certain and widely dispersed revenue loss wagered in the hope of triggering a contingent and deferred response from a narrow target. The article revisits the history of this proposal and the development of the argument in the last two decades. It then queries some impressions embedded in the current debate — that the proposal is for a tax cut, that a 30% rate on commercial profit is actually paid (or meant to be paid) by most companies, that the imputation system will negate much of the cost of the lost revenue and that most foreign investors will benefit from a reduced corporate rate. The article concludes that, while the proposal may be sensible for other reasons, the case currently being made is unconvincing.","PeriodicalId":330166,"journal":{"name":"Law & Society: Public Law - Tax eJournal","volume":"29 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-10-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131918693","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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