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.

Accepting Regional Zero: Nuclear Weapon Free Zones, U.S. Nonproliferation Policy and Global Security, 1957–1968

2015 ◽  
Vol 17 (2) ◽  
pp. 36-72 ◽  
Author(s):  
James Stocker
Keyword(s):  
Latin America ◽  
Nuclear Weapon ◽  
Security Policy ◽  
The United States ◽  
Nuclear Nonproliferation ◽  
Nuclear Strategy ◽  
The World ◽  
History Of ◽  
The U.S ◽  
Over Time

Nuclear weapon free zones (NWFZs) were an important development in the history of nuclear nonproliferation efforts. From 1957 through 1968, when the Treaty of Tlatelolco was signed, the United States struggled to develop a policy toward NWFZs in response to efforts around the world to create these zones, including in Europe, Africa, Latin America, and the Middle East. Many within the U.S. government initially rejected the idea of NWFZs, viewing them as a threat to U.S. nuclear strategy. However, over time, a preponderance of officials came to see the zones as advantageous, at least in certain areas of the world, particularly Latin America. Still, U.S. policy pertaining to this issue remained conservative and reactive, reflecting the generally higher priority given to security policy than to nuclear nonproliferation.

scholarly journals Measuring the Effects of Corporate Tax Cuts

2018 ◽  
Vol 32 (4) ◽  
pp. 97-120 ◽  
Author(s):  
Alan J. Auerbach
Keyword(s):  
Multinational Corporations ◽  
Income Tax ◽  
Capital Investment ◽  
Corporate Income Tax ◽  
Tax Law ◽  
Corporate Tax ◽  
The Law ◽  
Jobs Act ◽  
The Impact ◽  
Tax Cuts

On December 22, 2017, President Donald Trump signed the Tax Cuts and Jobs Act (TCJA), the most sweeping revision of US tax law since the Tax Reform Act of 1986. The law introduced many significant changes. However, perhaps none was as important as the changes in the treatment of traditional “C” corporations—those corporations subject to a separate corporate income tax. Beginning in 2018, the federal corporate tax rate fell from 35 percent to 21 percent, some investment qualified for immediate deduction as an expense, and multinational corporations faced a substantially modified treatment of their activities. This paper seeks to evaluate the impact of the Tax Cuts and Jobs Act to understand its effects on resource allocation and distribution. It compares US corporate tax rates to other countries before the 2017 tax law, and describes ways in which the US corporate sector has evolved that are especially relevant to tax policy. The discussion then turns the main changes of the Tax Cuts and Jobs Act of 2017 for the corporate income tax. A range of estimates suggests that the law is likely to contribute to increased US capital investment and, through that, an increase in US wages. The magnitude of these increases is extremely difficult to predict. Indeed, the public debate about the benefits of the new corporate tax provisions enacted (and the alternatives not adopted) has highlighted the limitations of standard approaches in distributional analysis to assigning corporate tax burdens.

A History of Interprofessional Education and Assessment at WesternU

2020 ◽  
pp. 286-310
Author(s):  
David N. Dickter ◽  
Daniel C. Robinson
Keyword(s):  
Interprofessional Education ◽  
Growth And Development ◽  
The United States ◽  
Health Sciences ◽  
Early History ◽  
Patient Centered ◽  
Education Practice ◽  
History Of ◽  
The U.S ◽  
Over Time

This chapter traces the early history and progress of a pioneering interprofessional practice and education (IPE) program at Western University of Health Sciences (WesternU), whose growth and development can be viewed in the context of the broader IPE field, that of a nascent movement within the United States to recognize and facilitate collaborative, patient-centered healthcare. This chapter provides some of the background and details from the early design years at WesternU. The IPE movement in the U.S. worked with general principles and broad conceptual outcomes such as safety and quality but it took time to delineate more specific guidelines and practices. Over the years, frameworks and standards for education, practice, and outcomes assessment have developed that have helped to guide the program. Similarly, WesternU has developed and refined its education and assessment methods over time.

scholarly journals Abuses and Penalties of a Corporate Tax Inversion

2019 ◽  
Vol 7 (1) ◽  
pp. 5
Author(s):  
James Yang ◽  
Leonard Lauricella ◽  
Frank Aquilino
Keyword(s):  
Multinational Corporations ◽  
International Taxation ◽  
Internal Revenue Service ◽  
Tax Law ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Tax Savings ◽  
Treasury Department ◽  
The U.S

There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as “corporate tax inversion”. This paper discusses the abuses and penalties of this phenomenon. It is rooted in some deficiencies in the U.S. tax law. This paper points out that the U.S. has the highest corporate tax rate in the world. It imposes tax on worldwide income. It permits deferral of tax on foreign-sourced income until dividends are repatriated back to the U.S. As a result, it creates tax loopholes. This paper reveals six actual cases of corporate tax inversion. This practice has triggered the Congress to enact §7874, the Internal Revenue Service (IRS) to issue Notices IR 2014-52 and IR 2015-79, and the U.S. Treasury Department to promulgate TD 9761. This paper investigates some details of these penalties. This paper further demonstrates an example in determining the amount of tax savings by engaging in a corporate tax inversion. It also offers many strategies.

scholarly journals Taxes and Capital Structure

2015 ◽  
Vol 50 (3) ◽  
pp. 277-300 ◽  
Author(s):  
Mara Faccio ◽  
Jin Xu
Keyword(s):  
Capital Structure ◽  
Income Taxes ◽  
Personal Income ◽  
Tax Rates ◽  
Personal Income Tax ◽  
Natural Experiments ◽  
Corporate Tax ◽  
Personal Taxes ◽  
Ex Post ◽  
Tax Payers

AbstractWe use nearly 500 shifts in statutory corporate and personal income tax rates as natural experiments to assess the effect of corporate and personal taxes on capital structure. We find both corporate and personal income taxes to be significant determinants of capital structure. Based on ex post observed summary statistics, across Organisation for Economic Co-Operation and Development (OECD) countries, taxes appear to be as important as other traditional variables in explaining capital structure choices. The results are stronger among corporate tax payers, dividend payers, and companies that are more likely to have an individual as the marginal investor.

scholarly journals Developments in Gender and Politics: A Call for Intersectionality

2019 ◽  
Author(s):  
Morgan Matthews
Keyword(s):  
Communities Of Practice ◽  
Political Institutions ◽  
Minority Groups ◽  
Political Identity ◽  
Women And Politics ◽  
Gender And Politics ◽  
History Of ◽  
The U.S ◽  
Over Time ◽  
Theoretical Developments

Since “women and politics” scholarship emerged in the 1970s, social, institutional, and theoretical developments have shaped the trajectory of U.S. scholarship in this field. First, the presence of women in formal politics has increased, albeit unevenly across parties and minority groups over time. Simultaneously, the capacity to study ‘political women’ has become supported through institutional mechanisms such as academic journals and communities of practice. Moreover, gender as a critical focus of analysis has been developed and refined. In the literature on women and politics, the shift from studying sex differences to interrogating gendered political institutions is especially salient. This institutional focus, along with recent intersectional studies of gender and politics, increases opportunities for cross-pollination of sociological and political science perspectives. In this review, I provide a brief history of the U.S. scholarship on gender and politics and map these relevant social, institutional, and theoretical advances. I highlight the value of recent intersectional contributions in this field and make the case for bringing partisanship – an increasingly salient political identity and structure – into intersectional approaches to gender and politics.

Race, Space, Time

Peyote Effect ◽  
2018 ◽  
pp. 169-176
Author(s):  
Alexander S. Dawson
Keyword(s):  
United States ◽  
Economic Development ◽  
African American ◽  
The United States ◽  
Short History ◽  
Spanish Inquisition ◽  
History Of ◽  
The Creation ◽  
The U.S ◽  
Over Time

We begin the book’s conclusion with the juxtaposition of two different stories of peyotism: the creation of an ecotourism business featuring Wixárika peyotism in Potrero de la Palmita, Nayarit, in 2010 and the short history of an African American peyotist church in Tulsa, Oklahoma, in the 1920s. The former is licit, enjoying support by a state committed to economic development, while the latter faced constant threats from the police before collapsing, in part due to its members’ fear of arrest. These two stories remind us of the central roles that place and time play in the history of peyotism across the U.S.-Mexican border, but they also force us to consider the ways that ideas about race have informed the battles over peyote in Mexico and the United States. Particularly striking is the fact that the racial prohibitions enacted by the Spanish Inquisition resonate with current law. Also notable is the fact that Mexicans and Americans have deployed similar ideas about race over time in their battles over peyote. This speaks to the underlying anxieties that indigeneity evokes in both societies, as well as the role that indigenous subjects have played in the creation of whiteness in both the United States and Mexico.

scholarly journals Finances of the Nation: Net Income Tax Rates and the Changing Progressivity of the Cash Tax/Transfer System

2021 ◽  
Vol 69 (2) ◽  
pp. 575-593
Author(s):  
Tahsin Mehdi ◽  
Brian Murphy
Keyword(s):  
Income Tax ◽  
Cash Transfers ◽  
Income Taxes ◽  
Transfer System ◽  
Tax Rates ◽  
Lower Income ◽  
Net Income ◽  
Effective Tax Rates ◽  
Tax System ◽  
Over Time

In this article, using new data released in 2019, Tahsin Mehdi and Brian Murphy examine changes in the progressivity of the federal and provincial income tax system, in conjunction with changes in the progressivity of federal and provincial cash transfers since 1992, by examining effective tax rates. Many of the major components of the system of income taxes and cash transfers have become somewhat more progressive collectively over time. This has resulted in an improved net tax position for lower-income taxfilers as well as the top third of taxfilers. On the other hand, taxfilers in the middle quintile have experienced a drop in their net tax position since 1992.

scholarly journals The Decreasing Trend in U.S. Cash Effective Tax Rates: The Role of Growth in Pre-tax Income

2020 ◽  
Author(s):  
Alexander Edwards ◽  
Adrian David Kubata ◽  
Terry Shevlin
Keyword(s):  
Convex Function ◽  
Avoidance Behavior ◽  
Tax Avoidance ◽  
Downward Trend ◽  
Tax Rates ◽  
Corporate Tax ◽  
Effective Tax Rates ◽  
Over Time ◽  
Stable Linear

We develop a linear corporate tax function where taxes paid are regressed on pre-tax income and an intercept. We show that if the intercept is positive, cash ETRs are a convex function of pre-tax income. We present large sample evidence consistent with this ETR-convexity. Thus, although firms may have stable linear tax functions (i.e., constant parameters in the linear tax model) representing stable tax avoidance behavior, ETRs can change over time because of growth in pre-tax income. Consequently, simply examining changes (or differences) in cash ETRs is nondiagnostic about whether tax avoidance has changed over time (or differs across firms). We illustrate our argument by showing that all of the observed downward trend in cash ETRs documented by Dyreng et al. (2017) can be explained by growth in pre-tax income. The wholesale concern about increased tax avoidance over time might be overstated.

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