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December 11, 2006
A Challenge to Conventional International Tax Wisdom
by Martin A. Sullivan
International tax policy is not written in black or white but rather in shades of gray.
November 21, 2006
Tax Analysts Sues the IRS for Enforcement Performance Reports
Tax Analysts on November 20 sued the IRS, asking a federal court to force the agency to comply with the Freedom of Information Act and provide “monthly performance reports.”
October 16, 2006
Is It Time to Liquidate LIFO?
by Edward D. Kleinbard, George A. Plesko, and Corey M. Goodman
This report discusses the role of the last-in, first-out (LIFO) inventory accounting method in the current tax system, both as a matter of practice and of policy.
October 5, 2006
Who Are the Suckers in the Tax System?
by Christopher Bergin
Our income tax code is a mess. And who are its biggest victims? The regular W-2 wage earners — be they doctors, lawyers, nurses, architects, plumbers, or teachers.
September 18, 2006
Professor Releases Summary of 2007 Inflation Adjustments That Affect Individuals
by James C. Young
James C. Young, a professor of accountancy at Northern Illinois University, has prepared the annual summary of inflation adjustments that affect individual taxpayers.
September 18, 2006
Tax Analysts Obtains Text of 1993 SmithKline Beecham Advance Pricing Agreement
Tax Analysts has obtained the text of an advance pricing agreement concluded in 1993 by the IRS and pharmaceutical company SmithKline Beecham, a predecessor of GlaxoSmithKline, to govern intragroup sales of the drugs Tagamet and Dyazide.
September 5, 2006
Murphy v. IRS Leaves Tax Community Reeling
A recent decision out of the Court of Appeals for the District of Columbia is not only one of the most significant tax decisions in decades, but also one of the most important constitutional cases in decades.
September 4, 2006
High-Tech Companies' Tax Rates Falling
by Martin A. Sullivan
Over the last decade, large U.S. technology companies have reduced by nearly 10 percentage points the effective tax rates reported in their financial statements.
August 21, 2006
Absurdist Humor and the Form-Substance Dialectic in Tax Law
by Douglas H. Frazer
The form-substance distinction has long been a philosophical, metaphysical, and jurisprudential conundrum.
August 21, 2006
Sales Factor Apportionment in California
by Jennifer Carr and Cara Griffith
In April 2006 the California Court of Appeal, Third Appellate District, held that Toys "R" Us Inc. may include only interest earned on financial instruments in the sales factor of the state's apportionment formula.
August 14, 2006
Why Eric Solomon Should Not Be Confirmed Assistant Treasury Secretary
Tax Notes has reported numerous letters in support of Eric Solomon's nomination as assistant secretary of the Treasury for tax policy. I can find nary a word spoken or written against him.
August 14, 2006
High-Tech Firms Bring Home $58 Billion
by Martin A. Sullivan
Most of the profits from the foreign operations of U.S. corporations are not taxed by the United States until they are sent home to the parent companies. So to avoid U.S. tax, many domestic companies bottle up large pools of cash in their foreign subsidiaries.
August 14, 2006
The Business Activity Tax Simplification Act: A Good Standard for Multistate Business
by Chris Atkins
H.R. 1956, the Business Activity Tax Simplification Act of 2005, would prohibit states from imposing a corporate tax (based on net income, gross receipts, net worth, and so forth) on any corporation that has no physical presence (property or employees) in the state.
August 14, 2006
The First Wives' Club
by Lee A. Sheppard
Your correspondent was once asked by a television interviewer whether there was a "legitimate" reason to have a tax haven bank account. The short answer is no.
August 7, 2006
What's a New Democrat to Do?
by Joseph J. Thorndike
Democrats have a problem. Well, they have several problems, but arguably their biggest and most intractable is how to respond to economic globalization.
August 7, 2006
Drug Firms Move Profits to Save Billions
by Martin A. Sullivan
Moving profits from the United States to low-tax jurisdictions is the way prosperous U.S. pharmaceutical companies keep their taxes low. And that domestic-to-foreign shift has clearly accelerated in recent years.
July 31, 2006
I Don't Hate Wal-Mart, but I Don't Mind Taxing It
by David Brunori
I consider myself a good liberal on most public finance issues.
July 31, 2006
Taxes and Tinseltown
by Allen Kenney
A little more than 200 years ago, British colonists turned a campaign against oppressive taxes into a movement that gave rise to a new nation.
July 24, 2006
A More Intelligent Economic Substance Doctrine
by Lee A. Sheppard
What if the medium were the message?
July 17, 2006
Oysters and Gumballs
by David Brunori
Last week the North Carolina General Assembly passed an $18.9 billion budget that's chock full of tax changes. The budget contains a measure that would refund 50 percent of all sales tax paid by stock car racing teams on purchases of in-car instrumentation and paint.
July 17, 2006
Economic Analysis: Despite Rapid Growth, Corporate Tax Receipts Fall Short
by Martin A. Sullivan
The recent growth in corporate tax revenue has been astounding. In 2003 Treasury collected only $132 billion in corporate income tax. By 2005 the figure had soared to $278 billion.
July 10, 2006
Should the IRS Be Shaking Down Pimps?
by Dustin Stamper
Tax reporters got a break from the arcane and mundane recently when Congress put two new words in their tax vocabulary: pimps and prostitutes.
July 10, 2006
A Century of Soaking the Rich
by Joseph J. Thorndike
In September the federal estate tax will turn 90. As lawmakers continue to ponder repealing this aged but inflammatory levy, they should consider its provenance.
July 10, 2006
A Century of Soaking the Rich
by Joseph J. Thorndike
In September the federal estate tax will turn 90. As lawmakers continue to ponder repealing this aged but inflammatory levy, they should consider its provenance.