Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.

How do you make taxpayers comply? This ethnography offers a vivid, yet nuanced account of knowledge making at one of Sweden's most esteemed bureaucracies - the Swedish Tax Agency. In its aim to collect taxes and minimize tax faults, the Agency mediates the application of tax law to ensure compliance and maintain legitimacy in society. This volume follows one risk assessment project's passage through the Agency, from its inception, through the research phase, in discussions with management to its final abandonment. With its fiscal anthropological approach, Shaping Taxpayers reveals how diverse knowledge claims - legal, economic, cultural - compete to shape taxpayer behaviour.

This is the first book that performs international and intertemporal comparisons of uniform tax progression with empirical data. While conventional measures of tax progression suffer from serious disadvantages for empirical analyses, this book extends uniform measures to progression comparisons of countries with different income distributions. Tax progression is analyzed in terms of Lorenz curve and Suits curve equivalents of net incomes and taxes. The authors derive six distinct definitions of the relation "is more progressive than", which are then utilized for an empirical analysis of 13 countries included in the Luxembourg Income Study (LIS). In two thirds of all international comparisons of tax progression, the authors report a clear ranking of the respective countries in terms of progression dominance. Tax based definitions of greater progressivity perform best. These observations are yet reinforced by statistical tests. The book also provides an account of the institutional background of the involved countries in order to facilitate the interpretation of the data. Moreover, the authors conduct intertemporal comparisons of tax progression for selected countries and perform a sensitivity analysis with respect to the parameterization of the equivalence scale.

This book offers a comprehensive guide to modern day taxation issues. It presents a thorough overview of many of the crucial aspects of applied taxation and current tax systems, and presents evidence that supports taxation as an important policy issue requiring immediate address globally. Contributions seek to address the core question of how to design a tax policy mix that can serve primarily efficiency, growth and possibly equity goals at a time where fiscal spending, for many economies, is not a viable option. Chapters provide a historical perspective on taxation, then go on to cover aspects of the modern theory of optimal taxation and tax design and provide valuable international perspectives on current tax practices and much required tax reforms. Empirical analysis on taxation and related economic data help the readers to understand how data-based observations and results are linked to the theory of taxation, and more importantly economic growth, before offering appropriate policy prescriptions. This book will be of interest to scholars and practitioners interested in learning more about taxation and why it matters today in the global economy.

"Research on Economic Inequality, Volume 10, Fiscal Policy, Inequality and Welfare" contains ten papers, both theoretical and applied, on tax progressivity and tax and transfer equity. Theory topics covered include consumption tax equity, alternative definitions of tax progressivity, horizontal equity and reranking. The applied work includes studies of Australia's consumption taxes, Israel's national insurance tax system, Mexican transfer system, Canadian tax equity, trends in US tax and transfer progressivity and a study of the impact of the repeal of the US marriage tax penalty.

The original theory of capital cost and capital structure put forward by Nobel Prize Winners Modigliani and Miller has since been modified by many authors, and this book discusses some of them. The book's authors have created general theory of capital cost and capital structure - the Brusov-Filatova-Orekhova (BFO) theory, which generalizes the Modigliani-Miller theory to encompass companies of an arbitrary age (and arbitrary lifetime). Despite the availability of this more general theory, the classical Modigliani-Miller theory is still widely used in practice. In this book, the authors for the first time generalize it for cases of practical relevance: for the case of variable profit; for the case of advance tax-on-profit payments and interest on debt payments; for the case of several tax-on-profit and interest on debt payments per period; and for the combination of all three effects. These generalizations lead to valuable theoretical results as well as significantly widen of practical application this theory in practice and increase of the quality of finance management of the company. As well, the book investigates the applications of said results in corporate finance, investments, taxation and ratings, where employing a generalized Modigliani-Miller theory can be very fruitful.

The 27 articles reprinted in this volume are among Peter Mieszkowski's most important contributions to public, urban and regional economics. Several of these pieces concern income distribution theory and policies for promoting equality in wages, housing and education.The first part of this book includes studies of labour markets, tax incidence and the distributive effects of trade unions and wage subsidies. Two important conclusions presented in these papers concern the local property tax: it is a tax on capital and it results in under-provision of local public goods. The second and third parts of the book address, respectively, the decentralization of cities and and tax reform. Issues discussed include: racial discrimination in housing markets, the design of land use regulation, the negative income tax, consumption taxes, and tax reform in transition countries, particularly Eastern European countries. These outstanding essays bring together, in an accessible form, the work of one of the most important scholars in the field of public finance and urban economics.

The Asian-Pacific countries as well as India and Russia offer multinational companies all the benefits of booming economies in a world of recession. However, the investor must be aware of the tax regime under which he will operate. This survey presents the rates, definitions of taxable income and the incentives available in a complete, yet concise form. It goes on to review tax minimisation strategies and concludes with a comparison of the overall tax burdens for investors in each country derived from the Devereux/Griffith formulae - a methodology well known within the EU, but applied to this region for the first time.

This book elucidates the murky realities of China's taxation system today, and advocates bold plans for change. Theorizing finance and taxation in relation to a national political system, the authors explain the current tangled-up realities of China's creaky, inherited and uneven tax system- and put forward a plan for radical change. This book will be of interest to finance professionals, economists, and scholars of the Chinese economy. The focus is to properly handle the three basic economic and social relations between the government and the market (and the enterprises as the main market entities), between the central and local governments, and between the public power system and the citizens. This book follows the research context of problem orientation - goal orientation - practical operation, and puts forward the ideas, basic goals and paths of fiscal system reform that adapt to the modernization of national governance.

This is the second edition of a tax reference which brings together information on the provisions of 58 tax treaties between 12 major trading nations - Australia, Brazil, Canada, France, Germany, Italy, Japan, the Netherlands, Spain, Switzerland, UK and USA. The guide for revenue officials and tax advisors examines the background of double tax agreements and how they are brought into force. Further sections deal with matters including equipment leasing, the problem of treaty overrides and taxation of sportsmen and entertainers, and transfer pricing.;Article by article, the book reproduces the text of the the OECD Model and provides a short additional commentary. This is followed by an analysis of each countries treaties with each of the other countries dealt with in the book, including details of where they deviate from the OECD model.;"Tax Treaty Networks" also provides help in interpreting special wording used in other treaties by any of the 12 treaty partners - which should also be useful in interpreting the wording of treaties made by countries outside the present scope of the book.

On 8 November 1995 we organized the conference Is Inheritance Legitimate? Ethical and Economic Aspects of Wealth Transfers at the University of Antwerp (UFSIA). The conference brought together economists, philosophers and other social scientists to discuss the issues of bequest and inheritance. The conference programme featured five invited contributions; the revised versions of these five papers consitute the core of this book (Chapters 2, 3, 4, 6, and 7). Also included in this book are the written versions of the comments presented by the two discussants (Chapters 5 and 8). We also gave the opportunity to the authors who defended two radically different opinions on bequest and inheritance to comment upon one another's position (Chapters 9 and 10). Chapter 1 serves as an introduction; it situates the debate on inheritance in a broader ethical and economic framework, and summarizes the main points of the book. The conference was organized as part of a research project funded by the Flemish Fonds voor Wetenschap'pelijk Onderzoek (project number G. 0032. 95). Within UFSIA the conference was hosted by the 'Vakgroep Arbeidseconomie' of the Studiecentrum voor Economisch en Sociaal Onderzoek (SESO) and the Centrum voor Ethiek. The secretarial staff of SESO, in particular Annernarie Bunneghem and Linda Teunkens, did an excellent job in organizing the conference. Patricia De Bruyn and Tom Schatteman were extremely helpful in preparing the manuscript for the publisher. Antwerp, January 1997. Guido Erreygers and Toon Vandevelde, Editors CONTENTS Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

"Charles Konigsberg has done a great service for American taxpayers-- giving all of us a clear, direct and meaningful guide to the $3 trillion of our money that goes to the government to fund programs that shape our daily lives (for better or worse.) For one used to wading through gobbledygook or impenetrable jargon, the plainspoken, straightforward actual English in this book is especially refreshing. Every American concerned about federal taxing and spending--Democrat, Republican or other, budget analyst or average citizen--should have this book." Norman Ornstein, Resident Scholar, American Enterprise Institute "This is an extremely useful book--both for those seeking a comprehensible introduction to the complexities of the federal budget and to practitioners needing a quick refresher course." Alice M. Rivlin, former Director, Office of Management and Budget, and Congressional Budget Office "Charles Konigsberg, who advised my good friend Pat Moynihan on fiscal policy, explains in clear and concise language why the United States is on a dangerous fiscal path, with entitlement programs, particularly the health care entitlements, growing at an unsustainable rate due to rapidly rising health care costs." Bob Kerrey, former Senator from Nebraska and current President of the New School ____________________________________________________________ America's Priorities explains in clear, concise, nonpartisan language how the U.S. government raises and spends $3 trillion per year. The book provides plain English explanations of the budget process, major Federal spending programs, Federal taxes, and the reasons for the major swing from deficits in the 1980s to surpluses in the late 1990s and back to rapidly increasing debt in the current decade. A broad spectrum of readers will find the book useful: journalists, political and financial commentators, the government and financial sectors, the academic community, and voters looking for a nonpartisan explanation of how our elected officials are prioritizing public resources. Charles S. Konigsberg has over two decades of bipartisan experience in the White House and U.S. Senate, having served as General Counsel at the Senate Finance Committee, Minority Chief Counsel at the Senate Rules Committee, Staff Attorney at the Senate Budget Committee, and 4 years as an Assistant Director at the Office of Management and Budget.

Valuing Intellectual Capital provides readers with prescriptive strategies and practical insights for estimating the value of intellectual property (IP) and the people who create that IP within multinational companies. This book addresses the crucial topic of taxation from a rigorous and quantitative perspective, backed by experience and original research that illustrates how large corporations need to measure the worth of their intangible assets. Each method in the text is applied through the lens of a model corporation, in order for readers to understand and quantify the operation of a real-world multinational enterprise and pinpoint how companies easily misvalue their intellectual capital when transferring IP rights to offshore tax havens. The effect contributes to the issues that can lead to budgetary crises, such as the so-called "fiscal cliff" that was partially averted by passage of the American Taxpayer Relief Act on New Year's day 2013. This book also features a chapter containing recommendations for a fair and balanced corporate tax structure free of misvaluation and questionable mechanisms. CFOs, corporate auditors, corporate financial analysts, corporate financial planners, economists, and journalists working with issues of taxation will benefit from the concepts and background presented in the book. The material clearly indicates how a trustworthy valuation of intellectual capital allows a realistic assessment of a company's income, earnings, and obligations. Because of the intense interest in the topic of corporate tax avoidance the material is organized to be accessible to a broad audience.

Sovereign states commonly use tax incentives in order to attract investment and capital from abroad. Although it has been recognized for many years that the forms and features of these incentives can often have harmful effects, there has not until now been a clear, in-depth, full-scale study of what these effects are, how they come about, and how they can be minimized or avoided. Within this volume, Carlo Pinto crystallises the extensive European and American literature in the field, locating his legal analysis in an EU law context that offers a framework within which tax lawyers in both government and business can find common ground. This volume builds an authoritative synthesis and proposal in its detailed discussions of all aspects of the theory and practice of tax competition, including the following: evidence of interjurisdictional tax competition in the US experience and what the EU can learn from it; methodologies to study tax competition; economic evidence of tax competition in Europe; Member States' "benchmark" tax systems; internal market distortion provisions of the EU Treaty (Articles 96 and 97) and relevant EMU provisions. It also examines the: applicability of state aid provisions (EC Treaty Article 87) to direct tax measures; the EU "Code of Conduct" Group; OECD countermeasures against harmful tax competition; and CFC legislation. In the course of his presentation the author analyses various tax regimes and court cases from most EU Member States, outlining the issues and clarifications each brings to the central questions. His final proposal demonstrates that the beneficial effects of tax competition - decrease in direct tax burden, improved efficiency in public administration, enhancement of employment and development - need not be fraught with the risk of fiscal degradation. This is a significant development in the success of the projected harmonisation of taxation in the European Union.

This book covers the Tax Treaties which The People's Republic of China has signed with various nations of the European Region. This book is a collection of the treaties, supplementary materials, and selected implementing circulars. It is edited and ordered according to geographical/economic criteria and accompanied with integrated with tables, domestic tax systems reports, and accompanying circulars and treaty model texts. This book has never been compiled for Chinese tax treaties before, providing a new resource for firms and researchers to access the materials with ease. This book has the potential to be a part of a volume on China double tax treaties, and the book will encompass the entirety of China's Global Tax treaties. The intended readership of this book will be primarily professionals who are working in both the international accounting and legal industries. These readers frequently reference the treaties through the course of their normal business for the purpose of forming optimum tax structures and corporate structuring. However, it is also foreseeable that this book will be of interest to academic researchers in multiple fields from geo-politics, accounting, legal to economics.

"Advances in Taxation" publishes articles dealing with all aspects of taxation. Articles can address tax policy issues at the federal, state, local, or international level. The series primarily publishes empirical studies that address compliance, computer usage, education, legal, planning, or policy issues. These studies generally involve interdisciplinary research that incorporates theories from accounting, economics, finance, psychology, and/or sociology. Although empirical studies are primarily published, analytical and historical manuscripts are also welcome.

The six papers in this vohune represent state-of-the-art empirical and conceptual research on various aspects of the taxation of multinational corporations. They were commissioned for and presented at a conference organized by Price Waterhouse LLP on behalf of the International Tax Policy Forum, held in Washington, DC in March, 1994. The ftrst four papers were originally published in the May, 1995 issue of International Tax and Public Finance. The Slemrod paper appeared in the Policy Watch Section of the November, 1995 issue of that journal. The foregoing papers were subject to the normal refereeing procedures of the journal, and the summaries that follow are drawn from there. The Leamer paper has not been previously published. Altshuler and Mintz examine one aspect of the 1986 u. s. Tax Reform Act --the change in the rules for the allocation of interest expense between domestic-(U. S. ) and foreign-source income. In the absence of rules, a parent with excess credits could reduce U. S. tax liability by allocating interest expense toward itself; thus reducing its taxable domestic income without any compensating increase in either the U. S. tax due on foreign-source income or the foreign tax due (which is independent of U. S. rules).

The main objective of this book is to restate the important theories and evidence from economic analysis concerning intergovernmental fiscal issues. More importantly, the second objective of the book is to identify gaps in knowledge, empirical uncertainties, and missing theoretical structures and then to establish a preliminary agenda for new research on this topic. The book is organized in two sections. The first covers the core body of intergovernmental fiscal relations, including optimal size for jurisdictions and assignment of public sector functions, the formulation and execution of tax policy in an intergovernmental setting, and the appropriate structure and use of intergovernmental transfers. In the second section, the core knowledge is applied to four major policy areas: education, welfare, fiscal interaction in urban areas, and economic development. In thinking about a new research agenda, the authors call for more current and authoritative estimates of fiscal incidence, including interjurisdictional spillovers, for more fundamental research about the federation process and effects of consolidation, for new evidence about the long run, general equilibrium effects of interjurisdictional competition, and for basic research about the choice process and establishment of intergovernmental fiscal institutions and policies by federal and subnational governments.

In the latest volume of Advances in Taxation, series editor John Hasseldine presents studies from expert contributors exploring topics such as: corporate tax planning, tax-related accounting misstatements and uncertain tax positions, financial statement readability, the tax effects of a major pension scheme change, and non-professional investor and taxpayer judgments and perceptions. Reporting peer-reviewed research contributions from North America and the U.K., this volume is essential reading for those looking to keep abreast of the most recent research, including empirical studies using a variety of research methods from different institutional settings and contexts.