Tax Law: Practitioner Series eJournal最新文献

筛选
英文 中文
The Standard Business Deduction
Tax Law: Practitioner Series eJournal Pub Date : 2018-07-10 DOI: 10.2139/SSRN.3211427
K. Thomas
{"title":"The Standard Business Deduction","authors":"K. Thomas","doi":"10.2139/SSRN.3211427","DOIUrl":"https://doi.org/10.2139/SSRN.3211427","url":null,"abstract":"This paper describes a proposal for a standard business deduction (\"SBD\") for small businesses. The SBD would work like the regular standard deduction. The latter is a fixed amount that is claimed in lieu of claiming itemized deductions below the line. The SBD would be a fixed amount that is claimed above the line in lieu of deducting actual business expenses. Taxpayers claiming the SBD would report their gross business earnings, subtract the SBD, and arrive at net business income. No Schedule C would be necessary. Like the regular standard deduction, claiming the SBD would be optional for the taxpayer. If a taxpayer’s actual business expenses exceeded the SBD, he could instead opt to claim those expenses. \u0000 \u0000An SBD would greatly simplify the tax system for small business owners. Taxpayers who chose to claim it could be relieved of the burden of tracking business expenses during the year and could self-prepare their tax returns without the need for expensive tax preparation assistance. Not only would the SBD reduce socially wasteful taxpayer compliance costs, but it would also reduce IRS enforcement costs. Such simplification should be attractive to policymakers on both sides of the aisle and would benefit the government and taxpayers alike.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"118 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-07-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130967036","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}
引用次数: 0
Judging the New International Tax Regime: Testimony Before the U.S. Senate Committee on Finance 评判新的国际税收制度:在美国参议院财政委员会的证词
Tax Law: Practitioner Series eJournal Pub Date : 2018-04-24 DOI: 10.2139/SSRN.3171849
Rebecca M. Kysar
{"title":"Judging the New International Tax Regime: Testimony Before the U.S. Senate Committee on Finance","authors":"Rebecca M. Kysar","doi":"10.2139/SSRN.3171849","DOIUrl":"https://doi.org/10.2139/SSRN.3171849","url":null,"abstract":"The 2017 tax law made significant changes to the way the United States taxes multinational corporations on their cross-border income. The new legislation has, however, failed to solve old problems in the international system and also opened the door to new ones.The serious problems created, or left unaddressed, by the new regime, include the following: (1) The new international rules aimed at intangible income incentivize offshoring and largely preserve the profit shifting problem; (2) the new patent box regime will likely not increase innovation, causes WTO problems, and can be easily gamed; (3) the new inbound rules have too generous thresholds and can be readily circumvented; and (4) the new regime falls short of true international tax reform. This is the author's written testimony before the U.S. Senate Committee on Finance, at an April 24, 2018 hearing on the recent tax legislation.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-04-24","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"128381447","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}
引用次数: 2
Using Machine Learning to Predict Outcomes in Tax Law 使用机器学习预测税法结果
Tax Law: Practitioner Series eJournal Pub Date : 2017-12-15 DOI: 10.2139/ssrn.2855977
B. Alarie, Anthony Niblett, Albert H. Yoon
{"title":"Using Machine Learning to Predict Outcomes in Tax Law","authors":"B. Alarie, Anthony Niblett, Albert H. Yoon","doi":"10.2139/ssrn.2855977","DOIUrl":"https://doi.org/10.2139/ssrn.2855977","url":null,"abstract":"Recent advances in artificial intelligence and machine learning have bolstered the predictive power of data analytics. Research tools based on these developments will soon be commonplace. For the past two years, the three of us have been working on a project called Blue J Legal. We started with a view to understanding how machine learning techniques can be used to better predict legal outcomes. In this paper, we report on our experiences so far. The paper is set out in four parts. In Part 1, we discuss the importance of prediction. In many fields, humans are outperformed by mechanical and algorithmic prediction. We explore this phenomenon and conclude that the legal field is no different. In Part 2, we discuss recent advances in machine learning that have generated powerful tools for prediction. These new methods outperform traditional statistical techniques in predicting outcomes. In Part 3, we describe the Blue J Legal project. We discuss how Blue J Legal is using these machine learning technologies to provide predictions in grey areas of tax law. We provide a number of examples to illustrate the strength of these predictions. In part 4, we discuss the broader possibilities for technologies such as those powering Blue J Legal. We foresee a world where information about legal rights and responsibilities is more affordable; where the informational asymmetries that lead to wasteful expenditure on litigation is reduced; and where regulators use these tools to create a more effective and efficient administration of government. A final section concludes.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"107 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-12-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131897210","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}
引用次数: 28
Formalizing the Code 规范准则
Tax Law: Practitioner Series eJournal Pub Date : 2017-06-15 DOI: 10.2139/ssrn.2987065
Sarah Lawsky
{"title":"Formalizing the Code","authors":"Sarah Lawsky","doi":"10.2139/ssrn.2987065","DOIUrl":"https://doi.org/10.2139/ssrn.2987065","url":null,"abstract":"The Internal Revenue Code is notoriously complex, both substantively and structurally. This article examines one source of structural complexity in the Internal Revenue Code: dependency among sections that stems from defined terms. In particular, the article examines what it terms the problem of “definitional scope”: when the structure of the Code leaves unclear to what a term refers. The article uses the problem of definitional scope as a case study to suggest that those who draft tax legislation should formalize proposed statutory language — translate it into logical terms — prior to its enactment. Formalization could help drafters avoid unintentional ambiguity and refine the language used in the statute; it could provide helpful guidance for those wishing to interpret the statute; and, most importantly, it could help move the law closer to legibility by a computer — that is, it could help on the journey to actual legal artificial intelligence.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"184 ","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-06-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"120874616","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}
引用次数: 10
The Managed Asset Portfolio Market Analysis in Litigation: Calculating Reliable Discounts for Lack of Marketability for Non-Controlling Family Limited Partnership Interests 诉讼中的管理资产组合市场分析:计算非控股家族有限合伙利益缺乏市场价值的可靠折扣
Tax Law: Practitioner Series eJournal Pub Date : 2017-01-07 DOI: 10.2139/ssrn.2285185
Peter C. Dawson
{"title":"The Managed Asset Portfolio Market Analysis in Litigation: Calculating Reliable Discounts for Lack of Marketability for Non-Controlling Family Limited Partnership Interests","authors":"Peter C. Dawson","doi":"10.2139/ssrn.2285185","DOIUrl":"https://doi.org/10.2139/ssrn.2285185","url":null,"abstract":"A new method for calculating reliable discounts for lack of marketability (DLOMs) for Limited Partner (i.e., non-controlling) family limited partnership (FLP) interests, which we term the Managed Asset Portfolio Market (MAPM) Analysis, is developed. DLOMs typically are the largest valuation adjustment in, and often the most contentious part of, appraisals of closely-held company interests, including FLPs. U.S. Courts (and SEC) require appraisal experts to calculate objective, market-based DLOMs (that satisfy the Courts’ “gatekeeping” test to be qualified as expert testimony in litigation). Appraisals of market value are rooted in Economics and, as such, are inseparably linked to an underlying analysis of supply and demand. Although economic theory and principles are not absent in business valuation theory and practice, a market analysis often is only an implicit, and at times an unrecognizable, part of them. The MAPM Analysis is explicitly built upon an underlying economic foundation of market supply and demand, which, in conjunction with publicly-traded market data, provides a relevant and reliable market basis for estimating DLOMs for FLPs.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"72 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-01-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"127174638","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}
引用次数: 3
Tax Controversy Corner: The New ‘Partnership Representative’ 税收争议角:新的“合伙人代表”
Tax Law: Practitioner Series eJournal Pub Date : 2017-01-01 DOI: 10.2139/SSRN.2910585
Megan L. Brackney
{"title":"Tax Controversy Corner: The New ‘Partnership Representative’","authors":"Megan L. Brackney","doi":"10.2139/SSRN.2910585","DOIUrl":"https://doi.org/10.2139/SSRN.2910585","url":null,"abstract":"Under the new Bipartisan Budget Act of 2015 (the “BBA”), there are significant changes to the partnership audit rules, including changes to the procedures for assessment and collection of tax, and for judicial review.This column focuses on one specific procedural change, the elimination of the Tax Matters Partner (TMP), and the creation of the new Partnership Representative (PR).","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131167502","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}
引用次数: 0
Law and Macroeconomics: The Law and Economics of Recessions 法律与宏观经济学:经济衰退的法律与经济学
Tax Law: Practitioner Series eJournal Pub Date : 2016-09-01 DOI: 10.2139/ssrn.2828352
Yair Listokin
{"title":"Law and Macroeconomics: The Law and Economics of Recessions","authors":"Yair Listokin","doi":"10.2139/ssrn.2828352","DOIUrl":"https://doi.org/10.2139/ssrn.2828352","url":null,"abstract":"In this Article, I offer a macroeconomic perspective on law that reshapes the microeconomic perspective that currently dominates law and economics. I argue that 1. The economy works one way in ordinary economic conditions, in which supply capacity determines output, and a different way in deep recessions, in which demand for spending determines output. 2. Because the economy functions differently in deep recessions than in ordinary times, a law causes one set of effects in deep recessions and a different set of effects at other times. 3. Because the same law has different effects at different times, law should be different in deep recessions than in other times. Specifically, law should do more to promote spending in deep recessions than in ordinary economic conditions. Because the stakes of deep recessions are so high (tens of trillions of dollars in lost output, countless lives impaired, and political upheaval), I argue that the (significant) costs associated with introducing macroeconomics into law are worth bearing.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2016-09-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121373843","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}
引用次数: 12
Can Audits Encourage Tax Evasion? An Experimental Assessment 审计会助长逃税行为吗?实验评估
Tax Law: Practitioner Series eJournal Pub Date : 2016-03-16 DOI: 10.2139/SSRN.2724021
E. Satterthwaite
{"title":"Can Audits Encourage Tax Evasion? An Experimental Assessment","authors":"E. Satterthwaite","doi":"10.2139/SSRN.2724021","DOIUrl":"https://doi.org/10.2139/SSRN.2724021","url":null,"abstract":"Governments and tax administrators around the world rely on the premise that both random and non-random audits will deter tax evasion. This paper is the first in the tax compliance literature to present experimental evidence collected from U.S. residents that this premise may be, at least in part, wrong. Counter-intuitively, I find that random audits encourage taxpayers to cheat more. Where audits were framed as being “random”, participants increased their levels of evasion in the tax periods immediately following the audit. This effect, however, did not plague audits that were framed for participants as being non-random. When a separate group of participants faced audits in which detected evasion could “flag” a participant for one or more future audits, participants cheated less in the periods immediately following the audit. Overall, average compliance in response to non-random audits systematically and significantly dominated average compliance in response to random audits. This result remained robust to the addition of a series of demographic controls as well as the inclusion of participant and time fixed effects. By revealing strong behavioral responses to the way tax audits are presented, this paper (1) opens important new avenues for experimental and controlled field trial research on audit dynamics, and (2) underscores the potential benefits to tax administrators of being more transparent with taxpayers about the nature of audit selection.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2016-03-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"129371788","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}
引用次数: 5
Changes? BEPs, Transfer Pricing for Intangibles, and CCAS 变化?bep,无形资产转让定价和CCAS
Tax Law: Practitioner Series eJournal Pub Date : 2016-03-08 DOI: 10.2139/ssrn.2744730
Y. Brauner
{"title":"Changes? BEPs, Transfer Pricing for Intangibles, and CCAS","authors":"Y. Brauner","doi":"10.2139/ssrn.2744730","DOIUrl":"https://doi.org/10.2139/ssrn.2744730","url":null,"abstract":"The article argues that the BEPS project has made only minimal progress in its work on the transfer pricing for intangibles, despite the prominence of the issue. More specifically, it achieved none but increased confusion and incoherence in the context of the specific rules for CCAs.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"5 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2016-03-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"133602340","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}
引用次数: 1
Community Obligations in International Taxation 国际税收中的社区义务
Tax Law: Practitioner Series eJournal Pub Date : 2016-02-23 DOI: 10.2139/SSRN.2736923
Tsilly Dagan
{"title":"Community Obligations in International Taxation","authors":"Tsilly Dagan","doi":"10.2139/SSRN.2736923","DOIUrl":"https://doi.org/10.2139/SSRN.2736923","url":null,"abstract":"This paper describes the multilateral efforts regarding four key concerns of the international community: prevention of double taxation, fighting \"harmful tax competition,\" sharing of information, and the \"gaps and frictions\" between the tax systems of various countries noted by the recent BEPS report. It then asks what, in fact, constitutes the community’s interest in the international tax area, arguing that where tax policy is concerned, there is no clear \"textbook answer\" regarding the best way to tax internationally.The paper criticizes two proxies which are often implicitly endorsed in order to evaluate international tax policy: cooperation among states, and the prevention of transaction costs and market failures. It argues that cooperation, contrary to conventional wisdom, is neither a goal in itself, nor is it a good enough proxy for the collective good. Cooperation should be supported only when it genuinely promotes the interest of the community as a whole, which is not necessarily the case in the four initiatives examined. As for transaction costs and market failures, although their elimination indisputably seems to be a community interest that should be pursued, correcting only some of them may raise a second best problem.","PeriodicalId":225629,"journal":{"name":"Tax Law: Practitioner Series eJournal","volume":"19 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2016-02-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114973576","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}
引用次数: 1
0
×
引用
GB/T 7714-2015
复制
MLA
复制
APA
复制
导出至
BibTeX EndNote RefMan NoteFirst NoteExpress
×
提示
您的信息不完整,为了账户安全,请先补充。
现在去补充
×
提示
您因"违规操作"
具体请查看互助需知
我知道了
×
提示
确定
请完成安全验证×
相关产品
×
本文献相关产品
联系我们:info@booksci.cn Book学术提供免费学术资源搜索服务,方便国内外学者检索中英文文献。致力于提供最便捷和优质的服务体验。 Copyright © 2023 布克学术 All rights reserved.
京ICP备2023020795号-1
ghs 京公网安备 11010802042870号
Book学术文献互助
Book学术文献互助群
群 号:604180095
Book学术官方微信