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...

The thesis of this article is that the tax expenditure concept is grounded on an erroneous vision of the structure of an income tax system. The tax expenditure concept adopts a binary view of income taxation. It posits that there is an ideal or pure income tax system whose provisions are...

In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under 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...

As a public policy goal, moderation of financial instability has gained some prominence in the face of the current credit contraction. Not surprisingly perhaps, the role of tax policy in exacerbating instances of financial instability has begun to receive some attention in the tax-policy...

Factors such as the dividends-received deduction, the corporate AMT, and the Section 382 loss rules complicate the computation of NOLs and affect decisions needed in determining whether to carry the loss back.The NOL procedures provide an effective means of averaging the cyclical swings of...

The add-backs, adjustments, and other computations involved for individuals who incur a NOL, as well as the factors to consider in deciding if the carryback should be waived, can appear daunting.NOLs relate only to business income and deduction items, so an individual taxpayer must separate out...

Because policymakers may consider the state of the economy when setting taxes, endogeneity bias can arise in regression models that estimate relationships between economic variables and taxes. This paper quantifies the policy endogeneity bias and estimates the impact of R&D tax incentives on R&D...

Tax expenditure analysis (TEA) requires a baseline for identifying tax provisions that provide subsidies or incentives instead of serving to define the tax base and to implement the tax. With respect to the federal income tax, the baseline historically has been the Schanz-Haig-Simons (SHS)...