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...

This Article critically examines the efficiency of the quid pro quo test and its need for an exception in order to conform to the purpose of the charitable deduction; acting as a subsidy to those organizations the government feels provides a community benefit. Throughout the country,...

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...

The Congressional testimony provides a framework for thinking about the role of the charitable deduction in the federal income tax. As changes to the deduction are weighed by policymakers, it is important to consider: (1) the existing characteristics and policy tenets of the charitable...

There are two principal rationales for the charitable deduction. Depending upon choice of rationale, some tax reform changes are suggested and others are not. A base measurement rationale suggests eliminating the deduction for unrealized appreciation, keeping the benefit as a deduction and not a...

The Aloha State has been on the front line of justice for decades, including tax justice. This is the story of a two-decade-plus journey of the Hawaii earned income tax credit — including how the state might better serve financially challenged residents as they navigate the global pandemic’s...

This Article compares the ways in which the United States and the European Union limit the ability of state-level entities to subsidize their own residents, whether through direct subsidies or through tax expenditures. It uses four recent charitable giving cases decided by the European Court of...

Like many countries, Ghana provides tax incentives to encourage private investments and reduce the tax burden of certain sectors and the poor. However, these exemptions come at a cost. This chapter uses data provided by the Ministry of Finance of Ghana to estimate the cost of these exemptions,...