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Believing in Life After Loving: IRS Regulation of Tax Preparers 相信爱后的生活:美国国税局对税务编制者的监管
Pub Date : 2015-03-26 DOI: 10.5744/ftr.2015.1005
A. Levy
Nearly anyone can be a tax preparer. There is no test to pass or code of ethics to follow. With few barriers to entry, the field of tax preparation has drawn unscrupulous players, many of whom prey on low-income families who claim the earned-income tax credit. In 2011, the IRS endeavored to regulate the anything-goes world of tax preparation. But a group ofsmall-government activists at the Institutefor Justice challenged the IRS's regulations in federal court. And they won. The U.S. Court of Appeals Jbr the D.C. Circuit struck down the regulations as beyond the I.R.S.'s authority under section 330 of Title 31 of the United States Code. In the wake of that decision, Loving v. IRS, the only path fbrward for advocates of taxpayer protection is for Congress to explicitly empower the IRS to regulate swindlers posing as tax professionals. This Article is, fundamentally, a story of political and judicial failure in the age of small government absolutism. In a different era, federal oversight of unscrupulous tax preparers who have represented the blandest kind ofcommon sense. But the Institute for Justice was able to convince a panel ofjudges on what is widely regarded as the second most influential court in the country that IRS oversight of tax preparers is unlawful. The government's litigation strategy proved bumbling and ill-considered, it was easily outmaneuvered by its ideologically-driven adversary. In the Article, I provide background on the IRS regulations and the process by which they were developed; I detail the pervasive fraud and incompetence that motivated the IRS to act: I explore the Institute for Justice's push to invalidate the regulations in court, and I look at the arguments it made outside the courtroom; I evaluate the state-level experience with tax preparer regulations to see what can be learned from these "laboratories of democracy "; and, finally, I discuss how to proceed in the aftermath of Loving.
几乎每个人都可以成为报税员。没有需要通过的测试,也没有需要遵循的道德准则。由于几乎没有进入壁垒,税务准备领域吸引了肆无忌惮的参与者,其中许多人以申请劳动所得税抵免的低收入家庭为猎物。2011年,美国国税局(IRS)努力对无所作为的报税界进行监管。但司法研究所的一群小政府活动人士在联邦法院对国税局的规定提出了质疑。他们赢了。美国上诉法院和华盛顿特区巡回法院驳回了这些规定,认为它们超出了国税局的管辖范围《美国法典》第31编第330条赋予的权力。在Loving诉美国国税局(IRS)一案的裁决之后,对纳税人保护的倡导者来说,唯一的出路是国会明确授权美国国税局(IRS)监管冒充税务专业人士的骗子。从根本上说,这篇文章是一个关于小政府专制时代政治和司法失败的故事。在另一个时代,联邦政府监管肆无忌惮的报税人,他们代表着最平淡无奇的常识。但司法研究所(Institute for Justice)能够说服被广泛认为是美国第二大最有影响力的法院的一个法官小组,让他们相信美国国税局对报税人的监管是非法的。政府的诉讼策略被证明是笨拙和欠考虑的,它很容易被意识形态驱动的对手打败。在文章中,我提供了有关美国国税局法规的背景和制定过程;我详细描述了促使国税局采取行动的普遍欺诈和无能:我探讨了司法研究所(Institute for Justice)在法庭上推动这些规定无效的做法,并研究了它在法庭外提出的论点;我评估了州一级的税务人员监管经验,看看可以从这些“民主实验室”中学到什么;最后,我讨论了如何在失恋后继续前进。
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引用次数: 7
Market-Oriented Models of Social Housing as Tools for Social Mix: The Case of Bergamo 以市场为导向的社会住房模式作为社会组合的工具:以贝加莫为例
Pub Date : 2015-02-19 DOI: 10.2139/ssrn.2816262
Emanuele Belotti
The proliferation of market-oriented models of social housing has characterised the rearrangement of housing policy in Italy. These new housing models aimed to differentiate a supply of public housing often presented as limited and ineffective by including specific groups from the middle class who struggle to access the rental market. The new models are thus associated with the notion of ‘social mix’, and the need to remedy the ambiguous effects of the traditional public housing system has been emphasised, especially in terms of the spatial concentration of low-income households. This analysis focuses on the rearrangement of housing policy in the context of Bergamo, Lombardy’s middle-sized city, by analysing the implementation of a new socially rented housing model, namely moderate rental, and evaluating its effectiveness as a tool of tenure diversification within mass housing neighbourhoods which show high concentrations of low-income population. Through focusing the investigation on this case study, the research aims to contribute to bridging the gap in the scientific literature regarding the importation of social-mix policies into the South European context.
以市场为导向的社会住房模式的扩散已成为意大利住房政策重新安排的特征。这些新的住房模式旨在通过纳入难以进入租赁市场的中产阶级的特定群体,来区分通常被认为有限和无效的公共住房供应。因此,新模式与“社会混合”的概念有关,并强调需要纠正传统公共住房系统的模糊影响,特别是在低收入家庭的空间集中方面。本分析侧重于伦巴第中等城市贝加莫住房政策的重新安排,通过分析一种新的社会租赁住房模式的实施,即适度租赁,并评估其作为大规模住房社区中租住权多样化工具的有效性,这些社区显示出低收入人口的高度集中。通过将调查重点放在这个案例研究上,本研究的目的是帮助弥合关于将社会混合政策引入南欧背景的科学文献中的差距。
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引用次数: 1
Rethinking the Tax-Revenue Effect of REIT Taxation 重新思考房地产投资信托基金税收的税收效应
Pub Date : 2015-01-21 DOI: 10.5744/ftr.2015.1007
Bradley T. Borden
Real estate investment trusts (REITs) have recently made headlines in major media outlets and have caught the attention of lawmakers and analysts because they erode the corporate tax base. REITs are not subject to the entity-level tax that typically applies to corporations. To avoid being taxed on real estate income, some corporations spin off real estate into REITs. After a REIT spinoff, such corporations rent the real estate from the REIT and continue to use it in their operations. Thus, a mere change in corporate form removes taxable income from the corporation (i.e., erodes the corporate tax base) and eliminates the entity-level tax on income from the spun-off real estate. This erosion of the corporate tax base concerns lawmakers (who have proposed prohibiting tax-free REIT spinoffs), some economists, and the media. Another concern is that the IRS has extended REIT classification to entities that hold nontraditional real estate, such as telecommunications infrastructure, billboards, oil and gas pipeline systems, timber, casinos, prisons, and data centers. The extension of REIT taxation to nontraditional real estate may not erode the corporate tax base because the assets may come from noncorporate entities. Thus, the tax-revenue effect of REIT taxation extends beyond REIT spinoffs and the erosion of the corporate tax base. Nonetheless, intuition suggests that more REIT spinoffs, the expansion of REIT taxation, and the growth of the REIT industry must erode the corporate tax base and significantly reduce government tax revenue. This Article challenges that intuition and presents two counterintuitive findings. First, it shows that REIT spinoffs can actually increase tax revenue even though they erode the corporate tax base. Second, it reveals that loss of tax revenue from REIT taxation primarily results from REITs forming from partnerships, not from REIT spinoffs. The Article concludes by recommending how these findings should influence discussions of REIT reform.
房地产投资信托基金(REITs)最近登上了各大媒体的头条,并引起了议员和分析人士的注意,因为它们侵蚀了企业的税基。房地产投资信托基金不需要缴纳通常适用于公司的实体税。为了避免对房地产收入征税,一些公司将房地产分拆成REITs。在房地产投资信托基金分拆后,这些公司从房地产投资信托基金租用房地产,并继续在其运营中使用它。因此,仅仅改变公司形式就可以消除公司的应税收入(即侵蚀公司税基),并消除分拆房地产收入的实体税。这种对企业税基的侵蚀令立法者(他们已经提议禁止免税的房地产投资信托基金分拆)、一些经济学家和媒体感到担忧。另一个担忧是,美国国税局已将房地产投资信托基金的分类扩展到持有非传统房地产的实体,如电信基础设施、广告牌、石油和天然气管道系统、木材、赌场、监狱和数据中心。将房地产投资信托税扩展到非传统房地产可能不会侵蚀公司税基,因为这些资产可能来自非公司实体。因此,房地产投资信托税的税收影响超出了房地产投资信托的分拆和公司税基的侵蚀。尽管如此,直觉表明,更多的房地产投资信托基金分拆、房地产投资信托基金税收的扩大以及房地产投资信托基金行业的增长必然会侵蚀企业税基,并大幅减少政府税收。本文挑战了这种直觉,并提出了两个反直觉的发现。首先,它表明房地产投资信托基金的分拆实际上可以增加税收收入,尽管它们侵蚀了企业税基。其次,它揭示了房地产投资信托基金税收的损失主要来自合伙成立的房地产投资信托基金,而不是房地产投资信托基金的分拆。文章最后建议这些发现应该如何影响REIT改革的讨论。
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引用次数: 3
Micro-, Small and Medium Enterprises in Tajikistan: Drivers of and Barriers to Growth 塔吉克斯坦的中小微企业:增长的动力和障碍
Pub Date : 2014-11-01 DOI: 10.2139/SSRN.2946686
Kanat Tilekeyev
This paper presents the results of a study of the micro-, small and medium enterprise (MSME) sector in Tajikistan, with a focus on its role in the economic growth of the country. Tajikistan has experienced a significant improvement in economic performance during the last decade. This growth is evident in sectors in which MSMEs operate, suggesting the need to better understand the sector and its role in national economic growth. The paper describes the results of a survey of 325 randomly selected, cluster-based enterprises in three key economic sectors in urban and rural areas across Tajikistan: retail trade and services, transportation and agriculture. The dataset provides detailed information on the personal characteristics of entrepreneurs, as well as specific factors influencing the growth of MSMEs, including labour, capital, information and barriers to growth. Analysis of the determinants of making investments, as well as the success of investment decisions of urban entrepreneurs, provides insight into the necessity of developing education opportunities on business and financial planning for MSME owners. Conclusions are presented to help guide policy and programmes that impact the MSME sector and the broader environment in which it functions.
本文介绍了对塔吉克斯坦微型、小型和中型企业(MSME)部门的研究结果,重点关注其在该国经济增长中的作用。塔吉克斯坦在过去十年的经济表现有了显著改善。这种增长在中小微企业经营的行业中很明显,这表明有必要更好地了解该行业及其在国民经济增长中的作用。本文描述了对塔吉克斯坦城乡三个关键经济部门(零售贸易和服务、交通运输和农业)中随机选择的325家集群型企业的调查结果。该数据集提供了关于企业家个人特征的详细信息,以及影响中小微企业成长的具体因素,包括劳动力、资本、信息和增长障碍。分析投资的决定因素,以及城市企业家投资决策的成功,可以深入了解为中小微企业主提供商业和财务规划教育机会的必要性。提出的结论有助于指导影响中小微企业部门及其运作的更广泛环境的政策和计划。
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引用次数: 4
Frédéric Bastiat as an Accountant 弗雷泽·巴斯夏是一名会计
Pub Date : 2014-05-11 DOI: 10.2139/SSRN.2435745
Robert W. McGee
Frederic Bastiat (1801-1850) is primarily known for his writings in economics, especially in the area of international trade. However, he worked as an accountant in his early years and some of his writings take an accounting approach. This paper will examine the influence of accounting on his writings. Particular attention will be paid to his accounting approach toward the measurement and relevance of trade deficits, his application of the theory of opportunity cost, which was ahead of its time, and how he used accounting principles in his debate with Proudhon on the justification of interest. A bibliography with links to other Bastiat studies is also included.
弗雷德里克·巴斯夏(Frederic Bastiat, 1801-1850)主要以其经济学著作而闻名,尤其是在国际贸易领域。然而,他早年是一名会计,他的一些作品采用了会计方法。本文将考察会计学对其著作的影响。我们将特别关注他对贸易赤字的计量和相关性的会计方法,他对领先于时代的机会成本理论的应用,以及他如何在与蒲鲁东关于利益正当性的辩论中使用会计原则。参考书目与其他巴斯夏研究的链接也包括在内。
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引用次数: 7
Conditional Average Treatment Effects and Decision Making 条件平均治疗效果与决策
Pub Date : 2014-03-26 DOI: 10.2139/ssrn.2388364
M. Samano
This paper develops a decision making empirical method to evaluate welfare programs accounting for heterogeneity of impacts. We find outcome predictive distributions for different subgroups of the population and use a characterization of second order stochastic dominance to give a policy recommendation conditional on covariates with minimal requirements on the social planner's utility function. Further, we can estimate quantile treatment effects within subgroups of the population. We apply this method to the Connecticut's Jobs First program and find subgroups for which the program did not maximize welfare even though some statistics may suggest the opposite and vice-versa.
本文发展了一种考虑影响异质性的福利项目决策实证方法。我们发现了人口中不同亚群的结果预测分布,并使用二阶随机优势的特征来给出以协变量为条件的政策建议,同时对社会规划者的效用函数要求最低。此外,我们可以在人群的亚组中估计分位数治疗效果。我们将这种方法应用于康涅狄格州的就业优先计划,并找到该计划没有最大化福利的子群体,尽管一些统计数据可能表明相反,反之亦然。
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引用次数: 1
Understanding Mechanisms Underlying Peer Effects: Evidence from a Field Experiment on Financial Decisions 理解同伴效应背后的机制:来自金融决策现场实验的证据
Pub Date : 2014-03-16 DOI: 10.2139/ssrn.2101391
Leonardo Bursztyn, Florian Ederer, Bruno Ferman, Noam Yuchtman
Using a high‐stakes field experiment conducted with a financial brokerage, we implement a novel design to separately identify two channels of social influence in financial decisions, both widely studied theoretically. When someone purchases an asset, his peers may also want to purchase it, both because they learn from his choice (“social learning”) and because his possession of the asset directly affects others' utility of owning the same asset (“social utility”). We randomize whether one member of a peer pair who chose to purchase an asset has that choice implemented, thus randomizing his ability to possess the asset. Then, we randomize whether the second member of the pair: (i) receives no information about the first member, or (ii) is informed of the first member's desire to purchase the asset and the result of the randomization that determined possession. This allows us to estimate the effects of learning plus possession, and learning alone, relative to a (no information) control group. We find that both social learning and social utility channels have statistically and economically significant effects on investment decisions. Evidence from a follow‐up survey reveals that social learning effects are greatest when the first (second) investor is financially sophisticated (financially unsophisticated); investors report updating their beliefs about asset quality after learning about their peer's revealed preference; and, they report motivations consistent with “keeping up with the Joneses” when learning about their peer's possession of the asset. These results can help shed light on the mechanisms underlying herding behavior in financial markets and peer effects in consumption and investment decisions.
通过对一家金融经纪公司进行的高风险现场实验,我们实施了一种新颖的设计,分别识别金融决策中社会影响的两个渠道,这两个渠道在理论上都得到了广泛的研究。当某人购买一项资产时,他的同伴可能也想购买它,这既是因为他们从他的选择中学习(“社会学习”),也是因为他拥有该资产直接影响其他人拥有该资产的效用(“社会效用”)。我们随机化选择购买资产的对等对中的一个成员是否执行了该选择,从而随机化他拥有该资产的能力。然后,我们随机化这对中的第二个成员是否:(i)没有收到关于第一个成员的信息,或者(ii)被告知第一个成员购买资产的愿望以及确定占有的随机化结果。这使我们能够估计相对于(没有信息的)控制组,学习加占有和单独学习的效果。研究发现,社会学习渠道和社会效用渠道对投资决策均具有统计学和经济学意义上的显著影响。一项后续调查的证据表明,当第一(第二)投资者在财务上成熟(财务上不成熟)时,社会学习效应最大;投资者报告称,在了解了同行所透露的偏好后,他们更新了对资产质量的看法;而且,当他们得知同龄人拥有资产时,他们的动机与“攀比”一致。这些结果有助于揭示金融市场中羊群行为的潜在机制以及消费和投资决策中的同伴效应。
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引用次数: 85
The (Surprising) Efficacy of Academic and Behavioral Intervention with Disadvantaged Youth: Results from a Randomized Experiment in Chicago 学业和行为干预对弱势青少年的(惊人的)效果:来自芝加哥随机实验的结果
Pub Date : 2014-01-01 DOI: 10.3386/W19862
P. Cook, K. Dodge, G. Farkas, Roland G. Fryer, Jonathan Guryan, Jens Ludwig, Susan E. Mayer, H. Pollack, L. Steinberg
There is growing concern that improving the academic skills of disadvantaged youth is too difficult and costly, so policymakers should instead focus either on vocationally oriented instruction for teens or else on early childhood education. Yet this conclusion may be premature given that so few previous interventions have targeted a potential fundamental barrier to school success: "mismatch" between what schools deliver and the needs of disadvantaged youth who have fallen behind in their academic or non-academic development. This paper reports on a randomized controlled trial of a two-pronged intervention that provides disadvantaged youth with non-academic supports that try to teach youth social-cognitive skills based on the principles of cognitive behavioral therapy (CBT), and intensive individualized academic remediation. The study sample consists of 106 male 9th and 10th graders in a public high school on the south side of Chicago, of whom 95% are black and 99% are free or reduced price lunch eligible. Participation increased math test scores by 0.65 of a control group standard deviation (SD) and 0.48 SD in the national distribution, increased math grades by 0.67 SD, and seems to have increased expected graduation rates by 14 percentage points (46%). While some questions remain about the intervention, given these effects and a cost per participant of around $4,400 (with a range of $3,000 to $6,000), this intervention seems to yield larger gains in adolescent outcomes per dollar spent than many other intervention strategies.
越来越多的人担心,提高弱势青年的学术技能过于困难和昂贵,因此政策制定者应该把重点放在青少年的职业指导上,或者放在儿童早期教育上。然而,鉴于之前很少有干预措施针对学校成功的潜在根本障碍:学校所提供的与在学术或非学术发展上落后的弱势青年的需求之间的“不匹配”,这个结论可能还为时过早。本文报道了一项双管齐下的随机对照试验,该试验为弱势青年提供非学术支持,试图根据认知行为疗法(CBT)的原则教授青少年社会认知技能,并进行密集的个性化学术补救。研究样本包括芝加哥南部一所公立高中的106名九年级和十年级男生,其中95%是黑人,99%有资格享受免费或减价午餐。参与将数学测试成绩提高了对照组标准偏差(SD)的0.65和全国分布的0.48个标准差,将数学成绩提高了0.67个标准差,似乎将预期毕业率提高了14个百分点(46%)。虽然关于干预的一些问题仍然存在,但考虑到这些影响和每位参与者约4,400美元的成本(范围在3,000至6,000美元之间),这种干预似乎比许多其他干预策略在每花费一美元的青少年结果方面产生更大的收益。
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引用次数: 102
Evaluation of the College Possible Program: Results from a Randomized Controlled Trial 大学可能计划的评估:来自随机对照试验的结果
Pub Date : 2013-10-01 DOI: 10.3386/W19562
Christopher Avery
This paper reports the results of a randomized trial of the College Possible program, which provides two years of college preparatory work for high school juniors and seniors in Minneapolis and St. Paul. The trial involved 238 students, including 134 who were randomly selected for admission to the program. The results indicate that the College Possible program significantly increased both applications and enrollment to both four-year colleges and selective four-year colleges; we estimate that initial enrollment at four-year colleges increased by more than 15 percentage points for program participants, but find little evidence of any effect of the program on ACT performance or college enrollment overall.
本文报告了一项随机试验的结果,该试验为明尼阿波利斯和圣保罗的高中三年级和四年级学生提供了两年的大学预科工作。该试验涉及238名学生,其中134人是随机选择进入该项目的。结果表明,“大学可能”计划显著增加了四年制大学和选择性四年制大学的申请和入学率;我们估计项目参与者在四年制大学的初始入学率提高了15个百分点以上,但几乎没有证据表明该项目对ACT成绩或大学总体入学率有任何影响。
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引用次数: 48
Individual Development Accounts and Post-Secondary Education: Evidence from a Randomized Experiment 个人发展账户与高等教育:来自随机实验的证据
Pub Date : 2013-04-30 DOI: 10.2139/ssrn.2460867
Michal Grinstein-Weiss, Michael Sherraden, W. Gale, W. Rohe, Mark Schreiner, Clinton Key
This paper presents evidence from a randomized field experiment testing the impact of a 3-year matched savings program on educational outcomes 10 years later. We examine the effect of an Individual Development Account (IDA) program on educational enrollment, degree completion, and increased education level. The IDA program, which ran from 1998 to 2003 in Tulsa, Oklahoma, provided low-income households with financial education and matching funds for qualified savings withdrawals, including a 1:1 match for educational uses. We find a significant impact on education enrollment and positive, but non-significant impacts on degree completion and increase in level of education. We also examine the interaction between gender and treatment assignment and find that the IDA had a strong positive effect on increased educational attainment for males, but not for females.
本文提供了一个随机现场实验的证据,该实验测试了3年匹配储蓄计划对10年后教育成果的影响。我们考察了个人发展账户(IDA)项目对教育入学率、学位完成率和教育水平提高的影响。国际开发协会项目于1998年至2003年在俄克拉何马州塔尔萨实施,为低收入家庭提供金融教育和符合条件的储蓄提款配套资金,包括1:1的教育用途配套资金。我们发现对教育入学率有显著影响,对学位完成率和教育水平的提高有显著影响,但对教育水平的提高没有显著影响。我们还研究了性别和治疗分配之间的相互作用,发现IDA对男性教育程度的提高有很强的积极影响,但对女性没有影响。
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引用次数: 2
期刊
ERN: Primary Taxonomy (Topic)
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