The History of the U.S. Foreign Tax Credit and Its Implications

2020 ◽  
Vol 26 (3) ◽  
pp. 489-539
Author(s):  
Saejoon Ahn
Keyword(s):  
Tax Credit ◽  
History Of ◽  
Foreign Tax Credit ◽  
The U.S

Unresolved Issues Regarding the U.S. Foreign Tax Credit: A Case of the United Kingdom Windfall Tax

2014 ◽  
Vol 12 (2) ◽  
pp. 1-15
Author(s):  
Beth Y. Vermeer ◽  
Brian R. Greenstein
Keyword(s):  
Supreme Court ◽  
Supreme Court Decision ◽  
Policy Implications ◽  
Courts Of Appeals ◽  
Tax Credit ◽  
The United Kingdom ◽  
Foreign Tax Credit ◽  
Tax Court ◽  
Circuit Courts ◽  
The U.S

ABSTRACT In May 2013, the U.S. Supreme Court decided PPL Corp. & Subsidiaries v. Comm'r to resolve a split between the Third and Fifth Circuit Courts of Appeals regarding whether the U.K. windfall tax constitutes a creditable tax under Internal Revenue Code (IRC) Section 901. The results of this case have policy implications reaching far beyond a one-time foreign tax credit of $488 million for the three U.S. companies affected. In the Supreme Court decision on the U.K. windfall tax, the justices affirmed the substance over form approach to the net gain criteria in the Treasury Regulations and, thus, agreed that the foreign taxes should be creditable in this case. However, the justices left open the interpretation of the predominant character test, leaving unresolved issues regarding how this test should be interpreted in future cases and, specifically, what effect outliers may have on future interpretations of the foreign tax credit regulations. Thus, the purpose of this paper is to describe the origins of the U.K. windfall tax; highlight the Tax Court, Circuit Courts of Appeals, and Supreme Court decisions; and discuss the potential consequences for future tax policy stemming from this issue.

Should the Ethanol Blender's Credit Be Eliminated?

2017 ◽  
pp. 1-36
Author(s):  
David Besanko ◽  
Melissa Ulan
Keyword(s):  
Supply And Demand ◽  
Motor Fuel ◽  
Point Of View ◽  
Tax Credit ◽  
Excise Tax ◽  
Legislative Action ◽  
History Of ◽  
One Year ◽  
The One ◽  
The U.S

In December 2010, one U.S. legislative action was largely overlooked in the popular press: the one-year extension of the 45-cent-per-gallon Volumetric Ethanol Excise Tax Credit (VEETC), commonly known as the “blender's credit.” Both proponents and opponents of the blender's credit liked to cite data to support their positions. Proponents pointed out the number of jobs created by new ethanol plants, while opponents cited unfavorable energy balances from the use of ethanol and the overall budgetary impact of the blender's credit. What was less clear—but potentially much more important than the selective data cited by advocates and critics of ethanol—was the overall impact of the blender's credit on the U.S. economy. In particular, to what extent did the ethanol subsidy—by influencing the allocation of resources to the ethanol market—act as a drag on efficiency in the U.S. economy? This case presents a history of ethanol in the U.S. and an overview of the market for ethanol-based motor fuel, including data on demand and supply fundamentals. It also discusses the broader U.S. energy market, as well as the U.S. market for corn. The case reviews other policy interventions besides the ethanol tax credit that have an impact on the market for ethanol-based motor fuel, such as tariffs and mandates. Finally, it surveys the ways other countries around the world, such as Brazil, have supported the use of ethanol-based fuel.Provides a vehicle for teaching the basic economic model of government subsidies using supply and demand curves. Enable students to determine the deadweight loss of the ethanol tax credit for the year 2006. Enables discussion of the possible benefits of the ethanol tax credit including reducing reliance on foreign oil and reducing carbon emissions. Careful interpretation of the economic evidence in the case is essential for students to develop a coherent point of view on these potential benefits.

An American Language

2018 ◽  
Author(s):  
Rosina Lozano
Keyword(s):  
United States ◽  
National Policy ◽  
The United States ◽  
Spanish Language ◽  
Spanish Speakers ◽  
Language Recognition ◽  
Political Language ◽  
Political Issue ◽  
History Of ◽  
The U.S

An American Language is a political history of the Spanish language in the United States. The nation has always been multilingual and the Spanish language in particular has remained as an important political issue into the present. After the U.S.-Mexican War, the Spanish language became a language of politics as Spanish speakers in the U.S. Southwest used it to build territorial and state governments. In the twentieth century, Spanish became a political language where speakers and those opposed to its use clashed over what Spanish's presence in the United States meant. This book recovers this story by using evidence that includes Spanish language newspapers, letters, state and territorial session laws, and federal archives to profile the struggle and resilience of Spanish speakers who advocated for their language rights as U.S. citizens. Comparing Spanish as a language of politics and as a political language across the Southwest and noncontiguous territories provides an opportunity to measure shifts in allegiance to the nation and exposes differing forms of nationalism. Language concessions and continued use of Spanish is a measure of power. Official language recognition by federal or state officials validates Spanish speakers' claims to US citizenship. The long history of policies relating to language in the United States provides a way to measure how U.S. visions of itself have shifted due to continuous migration from Latin America. Spanish-speaking U.S. citizens are crucial arbiters of Spanish language politics and their successes have broader implications on national policy and our understanding of Americans.

Asian Americans and Pacific Islanders Excel in Business but Not without Risks

2016 ◽  
Vol 14 (2) ◽  
pp. 77-90
Author(s):  
Bill Imada
Keyword(s):  
Asian Americans ◽  
Asian American ◽  
Immigration Policy ◽  
Pacific Islanders ◽  
Significant Growth ◽  
Current Trends ◽  
History Of ◽  
Mainstream Society ◽  
American Society ◽  
The U.S

In recent years, data has shown that there has been significant growth in Asian American Pacific Islander-owned (AAPI) enterprises. Driven by demographic changes, related in large part to the history of immigration policy, the AAPI population has been growing, and this has been accompanied by AAPI innovators and entrepreneurs leaving greater marks on American society and the U.S. economy. This growth, however, is not without risks and threats. The legacy of being “othered” by mainstream society means that AAPI success in business and in the corporate landscape can be met with resentment and criticism. This article explores the history of AAPI entrepreneurship and current trends. It also examines the challenges that the community may continue to face and offers recommendations on how to ensure continued growth and expanded opportunities for AAPIs in business.

A Concise History of the U.S. Army Signal Corps

1988 ◽  
Author(s):  
Kathy Roe Coker ◽  
Carol E. Rios
Keyword(s):  
Signal Corps ◽  
History Of ◽  
The U.S

History of Respiratory Illness at the U.S. Naval Academy

2001 ◽  
Author(s):  
Tammy L. Blankenship ◽  
Gary Gackstetter ◽  
Gregory C. Gray
Keyword(s):  
Respiratory Illness ◽  
Naval Academy ◽  
History Of ◽  
The U.S

The Arbitrary Foreign Tax Credit

2020 ◽  
Author(s):  
Jordan Barry ◽  
Ariel Jurow Kleiman
Keyword(s):  
Tax Credit ◽  
Foreign Tax Credit

Transocean and the History of Tax Inversions

2018 ◽  
Vol 34 (1) ◽  
pp. 1-12
Author(s):  
Susan M. Albring ◽  
Randal J. Elder ◽  
Mitchell A. Franklin
Keyword(s):  
Multinational Corporations ◽  
Economic Impacts ◽  
Income Taxes ◽  
Tax Rates ◽  
Corporate Tax ◽  
Corporate Income Taxes ◽  
History Of ◽  
Jobs Act ◽  
The U.S ◽  
Over Time

ABSTRACT The first tax inversion in 1983 was followed by small waves of subsequent inversion activity, including two inversions completed by Transocean. Significant media and political attention focused on transactions made by U.S. multinational corporations that were primarily designed to reduce U.S. corporate income taxes. As a result, the U.S. government took several actions to limit inversion activity. The Tax Cuts and Jobs Act of 2017 (TCJA) significantly lowered U.S. corporate tax rates and one expected impact of TCJA is a reduction of inversion activity. Students use the Transocean inversions to understand the reasons why companies complete a tax inversion and how the U.S. tax code affects inversion activity. Students also learn about the structure of inversion transactions and how they have changed over time as the U.S. government attempted to limit them. Students also assess the tax and economic impacts of inversion transactions to evaluate tax policy.

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