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...

This position paper of the IBFD Academic Task Force (hereinafter IBFD Task Force) relates to the OECD's work on BEPS Action 1 and is devoted to withholding tax aspects. This position paper provides possible solutions to the challenges presented to the international tax regime by the digital...

This article considers concerns about Australia's capital gains tax (CGT) discount (providing generally for a 50 per cent discount on taxation of gains of resident taxpayers other than companies from disposal of assets held for more than 12 months) related to fiscal adequacy, and horizontal and...

The merits of capital levies depend on the likelihood of repetition, the extent of anticipation, and its effects on distribution. The relevance of these features, which in varying degrees is underdeveloped or underappreciated in pertinent literatures, is elaborated and then considered with...

This brief essay outlines three benchmarks for evaluating alternative ways of taxing capital income, summarizes anticipatory, retroactive, and accrual-based proposals for reforming the taxation of derivatives, and offers guidelines for evaluating more limited reforms. It is intended as an...