It comes as no surprise to any observant person in this country that there is a wide disparity in our federal income tax treatment of persons who have differing incomes and financial resources. But while much has been written on tax law complexity and inefficiency, little or nothing has been...

This essay, scheduled to appear in the 2014 symposium issue of the Chapman Law Review, proposes enactment of a deduction to individuals for distributions received on stock in regular, or "C," corporations when the distributions are reinvested prior to the return date for the year of...

R&D tax incentives have become a widely used policy tool to promote business R&D. How do they shape firms’ incentives to invest in R&D? This paper contributes a methodology to construct forward-looking effective tax rates for an R&D investment that reflect the value of expenditure-based R&D...

This study explores corporate responses to 1993 legislation, implemented as section 162(m) of the Internal Revenue Code, that capped the corporate tax deductibility of top management compensation at $1 million per executive unless it qualified as substantially "performance-based." We detail the...

Estates and trusts are recognizing growing amounts of taxable income from “income in respect of a decedent” (or “IRD”). These are payments attributable to income earned by a decedent before death but received by an estate, trust, or other beneficiary after death, and taxed to that...

U.S.-based multinational corporations are calling for a tax holiday that would allow them to repatriate their foreign earnings at little tax cost. With over $1 trillion in earnings trapped offshore and untaxed by the U.S., these corporations characterize the proposed repatriation holiday as a...

To discourage firms from buying and selling tax deductions, Section 382 of the tax code limits the ability of one firm to use the ‘‘net operating losses'' (NOLs) of another firm that it acquires. Under the Troubled Asset Relief Program, the U.S. Treasury lent a large amount of money to...

The significant contribution of R&D to economic development and sustainability has been shown by various studies. Therefore, governments offer different fiscal instruments to attract R&D, especially regarding multinational entities (MNEs). One of the fiscal instruments are tax incentives for...

In order to calculate the burden of a comprehensive and progressive income tax falling on a certain income source, an apportionment scheme for the entire tax burden has to be chosen. This raises the question of how to deal with losses, which is relevant for Germany in view of the heavy losses...

This paper extends prior stock option literature by examining whether individual and corporate tax incentives are associated with the decision to hold shares acquired through option exercises. Aboody, Hughes, Liu, and Su (2008) refute the previously-held assumption that individuals immediately...