Samuelson (1964) showed that an income tax with an allowance for "economic" depreciation leads to asset valuations that are independent of their holders' marginal rates of tax. The tax system is then "neutral," in the sense that assets have the same value to all, irrespective of whether or at...

We consider the Merton problem with capital gain taxes. Since closed-form solutions are generally unavailable, we provide asymptotic expansions with small interest rate and other parameters, and then obtain an explicit investment and consumption strategy that effectively approximates the optimal...

It has become conventional wisdom, based partly on postulated portfolio adjustments by investors in risky assets, (1) to view an income tax as equivalent to a tax levied only on the risk free return to capital and as therefore equivalent to a wealth tax; and (2) to view the difference between an...

We develop an optimal tax timing model that takes into account asymmetric long-term and short-term tax rates for positive capital gains and limited tax deductibility of capital losses. In contrast to the existing literature, this model can help explain why many investors not only defer...

The objector in Anzamco Ltd v Commissioner of Inland Revenue (1983) 6 NZTC 61,522 was a company that had bought and developed a farm and sold it at a significantly higher price. The Commissioner taxed the profits under paragraphs 67(4)(a) and (e) of the Income Tax Act 1976. The court allowed the...

Judd's (1985) finding that the optimal long-run rate of tax on capital is zero—even if equity is an important social objective—has exerted substantial influence in academic and policy circles over the last quarter century. Only very recently has it become clear that Judd's zero-tax result...

This article examines two broad areas of capital gains tax (CGT) design in respect of the taxation of non-residents. The first area relates to the domestic design of the tax and focuses on whether a CGT should apply to all assets held by non-residents or to some limited subset of those assets...

The realization rule — which defers tax on asset gains and losses until a disposition — is a well-known flaw in the income tax. Tax scholars have long recognized that the rule causes inequity, inefficiency, complexity, and revenue loss; allows wealthy taxpayers to avoid the income tax; and...