One of the fundamental questions in business tax reform is whether to allow firms to immediately expense investments or require economic cost recovery. The conventional view is that expensing would generate stronger growth effects holding revenues constant. This view is rooted in traditional...

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...

The Baucus Discussion Draft on international tax reform includes a mechanism for taxing the accumulated foreign earnings of controlled foreign corporations as of the effective date that a new system for taxing foreign earnings is effective.This letter suggests changes to make this aspect of the...

Traditional economic theory holds that a business cash-flow tax is superior to a business income tax because it is more efficient and progressive. But much of the literature espousing this view does not explicitly specify the full range of assumptions underlying these claims, let alone explore...

This paper examines aspects of the policy design processes associated with the 1999 Review of Business Taxation. Given the breadth of the Review’s recommendations this paper focuses on two of its enacted proposals, the non-commercial loss (NCL) rules and the Simplified Tax System (STS). Whilst...

This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative...

The German corporate tax reform of 2008 has brought about important cuts in corporate tax rates, which were at the same time accompanied by significant changes in the determination of the tax base for both major German corporate taxes - corporate income tax and trade tax. The reform followed the...

We assess the business provisions of the 2017 Tax Cuts and Jobs Act, the biggest corporate tax cut in US history. We draw five lessons. First, corporate tax revenue fell by 40 percent due to the lower rate and more generous expensing. Second, firms with larger declines in their effective tax...