Tax sparing occurs when a country with a worldwide tax system grants its citizens foreign tax credits for the taxes that they would have paid on income earned abroad, but that escapes taxation by virtue of foreign tax incentives. The supporters of tax sparing argue that it is a form of foreign...

Each May, Forbes magazine publishes a study on tax misery. The Forbes Tax Misery Index is a proxy for evaluating whether tax policy attracts or repels capital and talent. It is computed by adding the top marginal tax rate for the corporate income tax, individual income tax, wealth tax,...

Originally published in The Tax Lawyer, this article provides a comprehensive review of existing corporate tax integration literature (e.g. economic journals, NBER working papers, Treasury and ALI Reports, law reviews, and other academic literature). It also explores partial integration under...

Political failure has long been the scapegoat for the increasing complexity of the income tax. Over the last few decades, confusion over the meaning of the term simplification appears to have become a second important obstacle to creating simpler tax laws. Because some tax complexity is...

Profits-only partnership interests grant service-providing partners an interest in the profits of a partnership but not its capital. Such interests are a proverbial double-edged sword: they create economic arrangements needed in business, but provide opportunities for inequitable tax reductions....

This Article begins by tracing the evolution of the accumulated earnings tax and the personal holding company tax from their origins to the mid-1980s. The Article then demonstrates the limited extent to which these corporate penalty taxes serve their historical purpose of preventing taxpayers...

Recent commentators have criticized the double taxation of distributed corporate income both as an inequitable tax that imposes greater tax burdens on individual shareholders than other taxpayers and as an inefficient tax that distorts the economic decisions of taxpayers. These scholars have...

This article examines Constantinides-strategy capital gains tax trading during earnings announcements in a Kyle trading market. Capital gains taxes discourage shareholders from selling after a runup. On the other hand, capital loss offsets encourage selloffs after a crash. Accordingly, prices...

The current international tax system diverges greatly from a theoretically ‘‘optimal’’ tax system. One reason for this discrepancy may be that politicians strive for other objectives rather than making tax rules that comply with the theoretical concepts of optimal taxation. In this...

Bei der Besteuerung nicht oder nur begrenzt handelbarer Dienstleistungen (wie z.B. lokale Postdienstleistungen) entfällt der Anpassungsdruck des internationalen Steuerwettbewerbs weitgehend, sodass etwaige Wettbewerbsverzerrungen insbesondere zwischen verschiedenen inländischen...