scholarly journals The Double Irish and Dutch Sandwich tax strategies: Could a general anti-avoidance rule counteract the problems caused by the utilisation of these structures?

2021 ◽  
Author(s):  
◽  
Danielle Thorne
Keyword(s):  
United States ◽  
Income Tax ◽  
Multinational Enterprises ◽  
Current System ◽  
The United States ◽  
Tax System ◽  
Tax Havens ◽  
Intangible Resources ◽  
And Control ◽  
Tax Structures

<p>This paper analyses the Double Irish and Dutch Sandwich tax structures used by large multinational enterprises. These structures enable companies to shift significant profits to offshore tax havens through the use of wholly owned subsidiaries in Ireland and the Netherlands. Application of the New Zealand General Anti-Avoidance rule in s BG 1 of the Income Tax Act 2007 reveals that any attempt to counteract these structures would be highly fact dependent. The paper concludes that it would be possible to apply the rule, but that there would be practical difficulties in relation to enforceability of the Commissioner’s ruling. A similar result was reached when applying the United States General Anti-Avoidance rule. The attempted application of the General Anti-Avoidance rules reveals a fundamental flaw in the income tax system. That is, the inability of the current system to regulate and control intangible resources and technology based transactions.</p>

scholarly journals The Double Irish and Dutch Sandwich tax strategies: Could a general anti-avoidance rule counteract the problems caused by the utilisation of these structures?

2021 ◽  
Author(s):  
◽  
Danielle Thorne
Keyword(s):  
United States ◽  
Income Tax ◽  
Multinational Enterprises ◽  
Current System ◽  
The United States ◽  
Tax System ◽  
Tax Havens ◽  
Intangible Resources ◽  
And Control ◽  
Tax Structures

<p>This paper analyses the Double Irish and Dutch Sandwich tax structures used by large multinational enterprises. These structures enable companies to shift significant profits to offshore tax havens through the use of wholly owned subsidiaries in Ireland and the Netherlands. Application of the New Zealand General Anti-Avoidance rule in s BG 1 of the Income Tax Act 2007 reveals that any attempt to counteract these structures would be highly fact dependent. The paper concludes that it would be possible to apply the rule, but that there would be practical difficulties in relation to enforceability of the Commissioner’s ruling. A similar result was reached when applying the United States General Anti-Avoidance rule. The attempted application of the General Anti-Avoidance rules reveals a fundamental flaw in the income tax system. That is, the inability of the current system to regulate and control intangible resources and technology based transactions.</p>

Tax Expenditures and the Tax Reform Act of 1969 in the United States

2022 ◽  
pp. 1-26
Author(s):  
Seiichiro Mozumi
Keyword(s):  
United States ◽  
Income Tax ◽  
Public Perception ◽  
Tax Reform ◽  
The United States ◽  
Tax Revenue ◽  
Tax System ◽  
Federal Income Tax ◽  
Federal Taxation ◽  
The Government

Abstract In the United States, tax favoritism—an approach that has weakened the extractive capacity of the federal government by providing tax loopholes and preferences for taxpayers—has remained since the 1930s. It has consumed the amount of tax revenue the government can spend and therefore weakened the possibility of the redistribution of fiscal resources. It has also made the federal tax system complicated and inequitable, resulting in undermining taxpayer consent. Therefore, since the 1930s, a tax reform to create a simple, fair, and equitable federal income tax system with the capacity to raise revenue has been long overdue. Many scholars have evaluated the Tax Reform Act of 1969 (TRA69), which Richard M. Nixon signed into law on December 30, 1969, as one of the most successful steps toward accomplishing this goal. This article demonstrates that TRA69 left tax favoritism in the United States. Furthermore, it points out that TRA69 turned taxpayers against the idea of federal taxation, a shift in public perception that greatly impacted tax reform in the years to follow.

Individual Income Tax Erosion: By Income Class in Japan

1979 ◽  
Vol 7 (3) ◽  
pp. 303-322
Author(s):  
Hiromitsu Ishi
Keyword(s):  
United States ◽  
Income Tax ◽  
The United States ◽  
Tax Law ◽  
Major Conclusion ◽  
Tax Base ◽  
Tax System ◽  
Distributional Effects ◽  
Individual Income ◽  
Income Class

In Japan, as well as in the United States, the introduction of special provisions of the tax law has resulted in erosion of the tax base and tax yield. It is expected that tax erosion tends to destroy the equity of the existing income tax system. In this article, estimates of income tax erosion by income class for 1972 and 1975 are made from Japanese tax data. The major conclusion of this study is that the distributional effects of erosion of the Japanese income tax are quite similar to those in the United States.

scholarly journals How Progressive is the U.S. Federal Tax System? A Historical and International Perspective

2007 ◽  
Vol 21 (1) ◽  
pp. 3-24 ◽  
Author(s):  
Thomas Piketty ◽  
Emmanuel Saez
Keyword(s):  
United States ◽  
United Kingdom ◽  
Income Tax ◽  
The United States ◽  
Tax Rates ◽  
Tax System ◽  
Tax Progressivity ◽  
The United Kingdom ◽  
Income Groups ◽  
The U.S

This paper provides estimates of federal tax rates by income groups in the United States since 1960, with special emphasis on very top income groups. We include individual and corporate income taxes, payroll taxes, and estate and gift taxes. The progressivity of the U.S. federal tax system at the top of the income distribution has declined dramatically since the 1960s. This dramatic drop in progressivity is due primarily to a drop in corporate taxes and in estate and gift taxes combined with a sharp change in the composition of top incomes away from capital income and toward labor income. The sharp drop in statutory top marginal individual income tax rates has contributed only moderately to the decline in tax progressivity. International comparisons confirm that is it critical to take into account other taxes than the individual income tax to properly assess the extent of overall tax progressivity, both for time trends and for cross-country comparisons. The pattern for the United Kingdom is similar to the U.S. pattern. France had less progressive taxes than the United States or the United Kingdom in 1970 but has experienced an increase in tax progressivity and has now a more progressive tax system than the United States or the United Kingdom.

scholarly journals Specificity of functionality of student loan system in the United States

2020 ◽  
pp. 20-27
Author(s):  
Zhanna Tropina
Keyword(s):  
Higher Education ◽  
United States ◽  
Student Loans ◽  
Current System ◽  
The United States ◽  
Student Loan ◽  
Federal Programs ◽  
Effective System ◽  
Loan System ◽  
And Control

The subject of this research is the current system of student loans in the United States. The author analyzes major federal programs for students, types of loans, loan service plans, conditions for receiving scholarship for education. Special attention is given to the specificity of formation of student loan funds of higher educational institutions, and effective system of supervision and control over the parties to the program by the Department of Education that represents government interests. The research employs the dialectical method of cognition, as well as general scientific methods of analysis, synthesis, analogy, etc. The following conclusions were made: the established in the United States system of student loans is sufficiently effective; despite ample opportunities for receiving quality higher education for those born into wealthy families, the United States student loan system affords an opportunity for receiving higher education to the representatives of all social groups.

scholarly journals Employment Structure and the Rise of the Modern Tax System

2022 ◽  
Vol 112 (1) ◽  
pp. 213-234
Author(s):  
Anders Jensen
Keyword(s):  
United States ◽  
Time Series ◽  
Income Distribution ◽  
Income Tax ◽  
The United States ◽  
Third Party ◽  
Tax Base ◽  
Tax System ◽  
Income Levels ◽  
Long Run

This paper builds a new microdatabase that covers 100 countries at all income levels and long-run time series in the United States (1870–2010) and Mexico ( 1960–2010) to document how the modern tax system arises over development. I establish a new set of stylized facts, which show that the income tax exemption threshold decreases in the income distribution as a country develops, tracking growth in the employee share of employment that occurs gradually further down the income distribution. Additional evidence supports the interpretation that the rise in third-party covered income through increases in employee share drives expansions of the income tax base over development. (JEL D31, H23, H24, H71, J22, J23, N40)

The Outer Limits of the Welfare State: Discrimination, Racism and Their Effect on Human Services

1980 ◽  
Vol 10 (1) ◽  
pp. 63-75
Author(s):  
Harold J. Wershow
Keyword(s):  
United States ◽  
Income Tax ◽  
Human Services ◽  
Value Added ◽  
The United States ◽  
Tax Reforms ◽  
Middle Classes ◽  
State Discrimination ◽  
Tax Structures ◽  
The Welfare State

The European social democracies have been more generous than the United States in social provision, including services to aged. The momentum of provision has slowed down in recent years. We suggest that prosperity which has led to use of foreign laborers in menial jobs has caused this slow down. The dynamics are similar to the historical U.S. use of “non-100% Americans” as our menial workers. Changes in social policy strategies are needed: 1) universal provision, rather than programs aimed at minorities, is needed to enlist support of stable working and middle classes; 2) tax reforms, which lower progressive income-tax structures for middle incomes, and value-added tax, may be necessary to overcome anti-tax ideologies; 3) clear priorities as to most necessary services must be established by the gerontological community.

scholarly journals Taxing Consumption and Other Sins

2007 ◽  
Vol 21 (1) ◽  
pp. 49-68 ◽  
Author(s):  
James R Hines
Keyword(s):  
United States ◽  
Open Economy ◽  
Income Tax ◽  
The United States ◽  
State Governments ◽  
Payroll Taxes ◽  
Consumption Taxation ◽  
The World ◽  
And Control ◽  
Consumption Taxes

Federal and state governments in the United States use income and payroll taxes as their primary tools to collect revenue. Relative to the United States, governments in the rest of the world rely much more heavily on taxing consumption. Heavy American reliance on income rather than consumption taxation has not served the U.S. economy well. The inefficiency associated with taxing the return to capital means that the tax system reduces investment in the United States and distorts intertemporal consumption by Americans. While the economic logic of consumption taxation is compelling even for a closed economy, it is even more powerful for an open economy exposed to the world capital market. Consumption taxes in the form of excises can be designed to help protect the environment and control other externalities. Excise taxes can also serve the function of more closely aligning tax burdens with the benefits that taxpayers receive from certain government services. Understandable concerns arise about the distributional consequences of consumption taxation, but a system that relies heavily on consumption taxes, particularly if accompanied by an income tax, can be as progressive as any income tax the United States would realistically want to adopt.

scholarly journals Further Evidence Supporting The Replacement Of The Federal Tax System With A Consumption Tax Base

2011 ◽  
Vol 4 (1) ◽  
pp. 12
Author(s):  
Julia K. Brazelton
Keyword(s):  
United States ◽  
Regression Analysis ◽  
Income Tax ◽  
The United States ◽  
Tax Structure ◽  
Consumption Tax ◽  
Tax Base ◽  
Tax System ◽  
Analysis Techniques ◽  
The Impact

This study examines the primary considerations accompanying implementation of a consumption-based federal tax system. Additionally, theoretical and empirical (including graphs, derivates, and regression analysis) techniques are used to evaluate a consumption tax structure in the United States. The evidence presented supports such a system; however, the publics misperceptions concerning the impact and mechanics and the legislative bodys unwillingness to entertain a consumption tax proposal will probably further delay serious consideration for replacement of the income tax with a consumption tax.

The Kennedy–Johnson Tax Cut of 1964, the Defeat of Keynes, and Comprehensive Tax Reform in the United States

2017 ◽  
Vol 30 (1) ◽  
pp. 25-61
Author(s):  
Seiichiro Mozumi
Keyword(s):  
United States ◽  
Tax Policy ◽  
Income Tax ◽  
Tax Reform ◽  
The United States ◽  
Legislative Process ◽  
Tax System ◽  
House Committee ◽  
Federal Income Tax ◽  
Treasury Department

Abstract:In 1964, President Lyndon B. Johnson, the successor of John F. Kennedy, signed into law the largest tax cut in U.S. history until 1981, the so-called Kennedy–Johnson tax cut. Many scholars have evaluated it as representative Keynesian tax policy; this article focuses on the effort of the Treasury Department, tax experts such as Stanley S. Surrey and Wilbur D. Mills, the chairman of House Committee on Ways and Means, to reform the federal income tax system comprehensively—making it simpler, fairer, and more equitable—and their defeat by the 1964 tax cut. Through the policymaking and legislative process, the Kennedy administration’s Council Economic Advisers defeated the Treasury and Surrey by domesticating Keynes’s ideas on tax policy. Until the 1964 passage of the tax cut, Mills, with his inconsistent action, abandoned the accomplishment of their ideal tax reform.

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