ERN: Tax Policy (Sub-Topic)最新文献

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Some Proposals for Interpreting the Tax 'Straddle' Rules 解读税收“跨界”规则的若干建议
ERN: Tax Policy (Sub-Topic) Pub Date : 2007-10-01 DOI: 10.2139/ssrn.3452917
E. Nijenhuis
{"title":"Some Proposals for Interpreting the Tax 'Straddle' Rules","authors":"E. Nijenhuis","doi":"10.2139/ssrn.3452917","DOIUrl":"https://doi.org/10.2139/ssrn.3452917","url":null,"abstract":"This article proposes a solution to a vexing problem of significance when the article was written in 2007, namely how to match up long and short positions in a tax straddle. It also addresses rarely discussed questions relating to the application of the tax straddle rules to liabilities and to positions in a corporation’s own stock, and proposes frameworks for answering those questions.<br><br>The tax “straddle” rules are important to taxpayers that engage in investment and trading activities because they are the principal rules of the Internal Revenue Code that deal with the hedging of positions in capital assets. The straddle rules are anti-abuse rules, generally intended to prevent taxpayers from deducting tax losses or expenses incurred with respect to an investment asset in the absence of corresponding economic costs, from aging the holding period for an investment asset from short-term to long-term in the absence of risk, and from converting unrelated short-term capital gain or ordinary income to long-term capital gain. They are very broad in scope. Their breadth is in some ways unfortunate, as they were extended only a few years after their original enactment to transactions in stock for which the rules are not ideally crafted.<br><br>There have been numerous changes in market practice and some changes in other related areas of the law since the straddle rules were first enacted in 1981. The most important amendments to the rules were made in 1986. In 2004, Congress made the first significant changes to the tax “straddle” rules in two decades. The 2004 amendments do not, for the most part, address some important conceptual questions that have arisen over the years, although the commentary on those amendments has made a number of them more visible. This article addresses some of those questions. The principal focus of the article is on the rules addressing timing and holding period arbitrage. <br><br>Part I discusses the history of the straddle rules and summarizes the rules. It is intended to give readers not familiar with the straddle rules a sense of how they have developed, without addressing many of the details important to applying the rules in practice. Readers familiar with the straddle rules may want to skim Part I, since it is intended to set up the issues and arguments made in Part II.<br><br>Part II of the article discusses the long-standing question of how to determine which positions held by a taxpayer are part of a straddle. It suggests a line of analysis that explains the limited answers we have to that question to date, and that provides answers consistent with most practitioners’ instincts for unanswered questions. Part III then considers some issues relating to the application of the straddle rules to liabilities. Part IV discusses the question of whether a position in a corporation’s own stock can give rise to a straddle.<br><br>","PeriodicalId":368747,"journal":{"name":"ERN: Tax Policy (Sub-Topic)","volume":"20 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2007-10-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114893237","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
Labour Taxation in the European Union - Convergence, Competition, Insurance? 欧盟的劳动税收——趋同、竞争、保险?
ERN: Tax Policy (Sub-Topic) Pub Date : 2003-04-03 DOI: 10.2139/ssrn.2071657
C. Martínez-Mongay
{"title":"Labour Taxation in the European Union - Convergence, Competition, Insurance?","authors":"C. Martínez-Mongay","doi":"10.2139/ssrn.2071657","DOIUrl":"https://doi.org/10.2139/ssrn.2071657","url":null,"abstract":"Carlos Martinez-Mongay outlines labour tax trends in the European Union over the last three decades. The analysis is based on macro data: the average effective tax rates on labour, consumption and capital. Different measures of effective tax rates on labour in EU Member States are calculated; they are compared with those in the USA and Japan and with the effective tax rates on consumption and capital. All the measures show that the tax burden on labour has increased in the EU over the last three decades both in absolute terms and in comparison to the effective tax rate on capital. Moreover, over the same period the tax rates on labour, consumption and capital have converged across EU countries. These trends largely depend on two factors: the increase in social spending and international tax competition. However, concerning the latter there is little evidence that changes in tax rates on labour are related to changes in tax rates on capital. This suggests that international co-movements of tax rates and tax revenues may be due to common structural changes underlying tax policies rather than to tax competition forces.","PeriodicalId":368747,"journal":{"name":"ERN: Tax Policy (Sub-Topic)","volume":"7 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2003-04-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115212275","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
Tax Experimentation 税收实验
ERN: Tax Policy (Sub-Topic) Pub Date : 1900-01-01 DOI: 10.2139/ssrn.3366581
M. Abramowicz
{"title":"Tax Experimentation","authors":"M. Abramowicz","doi":"10.2139/ssrn.3366581","DOIUrl":"https://doi.org/10.2139/ssrn.3366581","url":null,"abstract":"Random experiments could allow the government to test tax policies before enactment into general law. Such experiments can be revenue-neutral, with the tax authority ensuring ex post that average tax revenues received from taxpayers in the treatment and control groups are equal. Taxpayers might thus volunteer even for experiments that would broaden the tax base, for example by eliminating deductions. Continued participation by taxpayers in such experiments would indicate that the proposed reforms are efficient at least if externalities are disregarded. Non-revenue-neutral experiments raise greater concerns about horizontal inequity, but may be helpful in addressing questions about effects of tax rates and in increasing participation. <br>","PeriodicalId":368747,"journal":{"name":"ERN: Tax Policy (Sub-Topic)","volume":"65 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131029454","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
The Pros and Cons of Taxing Sweetened Beverages Based on Sugar Content 对含糖饮料征税的利弊
ERN: Tax Policy (Sub-Topic) Pub Date : 1900-01-01 DOI: 10.2139/SSRN.2947716
Norton Francis, D. Marron, Kim S. Rueben
{"title":"The Pros and Cons of Taxing Sweetened Beverages Based on Sugar Content","authors":"Norton Francis, D. Marron, Kim S. Rueben","doi":"10.2139/SSRN.2947716","DOIUrl":"https://doi.org/10.2139/SSRN.2947716","url":null,"abstract":"Governments are starting to use taxes to discourage consumption of sugary drinks. Those taxes typically scale with drink volume. But sugar content varies widely. This report analyses the potential benefits and costs of scaling these taxes to sugar content. Taxes based on sugar content reduce consumption more effectively than taxes on volume. They also encourage businesses to reduce sugar in their products. Broad-based volume or sales taxes on all soft drinks, however, raise revenue more efficiently. Policymakers thus face trade-offs between using these taxes to raise revenue and to discourage sugar consumption.","PeriodicalId":368747,"journal":{"name":"ERN: Tax Policy (Sub-Topic)","volume":"15 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114154542","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: 16
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