scholarly journals Interest Relief on Income Tax Debts: Canada Versus the United States

2021 ◽  
Vol 68 (4) ◽  
pp. 931-986
Author(s):  
Michael H. Lubetsky
Keyword(s):  
United States ◽  
Voluntary Disclosure ◽  
Income Tax ◽  
The United States ◽  
The Public ◽  
The Us ◽  
Fair Compensation ◽  
Willingness To Use ◽  
Tax Court ◽  
The Comparative Study

Subsection 220(3.1) of the Income Tax Act authorizes the minister of national revenue to waive or cancel interest on income tax debts. This power is typically exercised in four circumstances: where interest has accumulated owing to circumstances beyond a taxpayer's control; where the interest has accumulated owing to error or delay by the Canada Revenue Agency; where the accumulated interest causes hardship; or in the context of a voluntary disclosure. South of the border, section 6404 of the Internal Revenue Code authorizes the secretary of the Treasury to "abate" interest on tax debts. As a practical matter, discretionary interest relief under section 6404 is available only in very limited circumstances. The restrictive approach to discretionary interest relief is, however, offset by a greater array of interest-relieving provisions, as well as by the power of the secretary to "compromise" tax liabilities on various grounds, some of which overlap with grounds for interest relief recognized in Canada. This article compares the Canadian and US interest relief regimes, with a view to identifying aspects of the US regime that may merit further consideration in Canada. The differences in the US approach that are of particular interest include • a wider, and arguably more coherent, range of relieving provisions applicable to interest, particularly with regard to interest netting and carrybacks; • the jurisdiction of the United States Tax Court to review refusals to abate interest and/or to accept an offer in compromise; • dealing with situations of hardship and extraordinary circumstances under the aegis of the offer-in-compromise regime, which allows for consideration of the underlying tax liability in addition to the interest, and which also allows for relief to be made conditional on the taxpayer's future compliance with filing and payment obligations; • in certain older cases, a willingness to use interest relief to settle longstanding and complex tax disputes; and • the absence of statutory time limits on the power of the secretary to abate or compromise interest. The comparative study also reveals how Canada and the United States place different weight on policy rationales that underlie interest relief. Canada focuses mainly on ensuring that the consequences of non-compliance for individual taxpayers are fair and equitable. The United States, on the other hand, focuses more on rehabilitating non-compliant taxpayers in the long term, as well as ensuring that interest reflects fair compensation for such taxpayers' use of the public treasury's money—both of which could be given greater attention on this side of the border.

scholarly journals Selected US Tax Developments: Adams Challenge (UK) Limited: When Does a Treaty Provision Conflict with the Code?

2021 ◽  
Vol 69 (2) ◽  
pp. 655-667
Author(s):  
Michael J. Miller
Keyword(s):  
United States ◽  
Income Tax ◽  
The United States ◽  
Recent Case ◽  
Equal Footing ◽  
Treaty Provision ◽  
The Us ◽  
Tax Court

In the United States, statutes and treaties are on an equal footing. Thus, in the event of a conflict between a statute and a treaty, the treaty does not automatically take precedence over the statute. Moreover, the US courts go to great lengths to avoid finding the existence of any conflict. This article discusses a recent case in which the Tax Court held, among other things, that a punitive deduction-disallowance rule applicable solely to non-US persons did not conflict with the non-discrimination article of the income tax treaty in effect between the United States and Canada.

Interaction of Ukrainian Diaspora and the USA Government Regarding Celebration of Ukrainian Independence Day on January 22

2018 ◽  
Vol 1 (47) ◽  
pp. 136-145
Author(s):  
Halyna Shchyhelska
Keyword(s):  
United States ◽  
House Of Representatives ◽  
The United States ◽  
100Th Anniversary ◽  
Totalitarian Regime ◽  
The Public ◽  
Us Congress ◽  
The Us ◽  
Public Consciousness ◽  
The Usa

2018 marks the 100th anniversary of the proclamation of Ukrainian independence. OnJanuary 22, 1918, the Ukrainian People’s Republic proclaimed its independence by adopting the IV Universal of the Ukrainian Central Rada, although this significant event was «wiped out» from the public consciousness on the territory of Ukraine during the years of the Soviet totalitarian regime. At the same time, January 22 was a crucial event for the Ukrainian diaspora in the USA. This article examines how American Ukrainians interacted with the USA Government institutions regarding the celebration and recognition of the Ukrainian Independence day on January 22. The attention is focused on the activities of ethnic Ukrainians in the United States, directed at the organization of the special celebration of the Ukrainian Independence anniversaries in the US Congress and cities. Drawing from the diaspora press and Congressional Records, this article argues that many members of Congress participated in the observed celebration and expressed kind feelings to the Ukrainian people, recognised their fight for freedom, during the House of Representatives and Senate sessions. Several Congressmen submitted the resolutions in the US Congress urging the President of United States to designate January 22 as «Ukrainian lndependence Day». January 22 was proclaimed Ukrainian Day by the governors of fifteen States and mayors of many cities. Keywords: January 22, Ukrainian independence day, Ukrainian diaspora, USA, interaction, Congress

scholarly journals Income Tax Complexity Faced by Multinational Corporations: A Comparative Study of Canada, the United States, and Other Selected OECD Countries

2021 ◽  
Vol 69 (3) ◽  
pp. 745-790
Author(s):  
Susann Sturm
Keyword(s):  
United States ◽  
Multinational Corporations ◽  
Income Tax ◽  
Transfer Pricing ◽  
The United States ◽  
Oecd Countries ◽  
The Us ◽  
Tax Complexity ◽  
Medium Level ◽  
Foreign Corporations

This study examines the complexity of Canada's corporate income tax system from the perspective of multinational corporations and compares it with the complexity of the US system, also taking into account measures of complexity for 19 other member countries of the Organisation for Economic Co-operation and Development (OECD). The author finds that with regard to the Canadian tax code, the most complex laws are those on corporate reorganization, transfer pricing, and controlled foreign corporations, and with regard to the Canadian tax framework, the most complex areas are tax audits, tax-law enactment, and tax guidance. In comparison with other OECD countries, Canada is remarkably similar to the United States. Both countries have a medium level of overall complexity, and both have a more complex tax code but a less complex tax framework than other countries. However, a closer examination of the Canadian and US tax codes and tax frameworks reveals some significant differences in complexity levels, particularly in respect of certain tax laws.

scholarly journals Is COVID-19 the end of US hegemony? Public bads, leadership failures and monetary hegemony

2020 ◽  
Vol 96 (5) ◽  
pp. 1281-1303 ◽  
Author(s):  
Carla Norrlöf
Keyword(s):  
United States ◽  
Public Goods ◽  
The United States ◽  
World Health ◽  
The Public ◽  
The Us ◽  
Us Hegemony ◽  
Health Organization ◽  
Public Bads ◽  
The Relationship

Abstract COVID-19 is the most invasive global crisis in the postwar era, jeopardizing all dimensions of human activity. By theorizing COVID-19 as a public bad, I shed light on one of the great debates of the twentieth and twenty-first centuries regarding the relationship between the United States and liberal international order (LIO). Conceptualizing the pandemic as a public bad, I analyze its consequences for US hegemony. Unlike other international public bads and many of the most important public goods that make up the LIO, the COVID-19 public bad not only has some degree of rivalry but can be made partially excludable, transforming it into more of a club good. Domestically, I demonstrate how the failure to effectively manage the COVID-19 public bad has compromised America's ability to secure the health of its citizens and the domestic economy, the very foundations for its international leadership. These failures jeopardize US provision of other global public goods. Internationally, I show how the US has already used the crisis strategically to reinforce its opposition to free international movement while abandoning the primary international institution tasked with fighting the public bad, the World Health Organization (WHO). While the only area where the United States has exercised leadership is in the monetary sphere, I argue this feat is more consequential for maintaining hegemony. However, even monetary hegemony could be at risk if the pandemic continues to be mismanaged.

Non-Standard Work in Two Different Employment Regimes

2004 ◽  
Vol 18 (2) ◽  
pp. 321-348 ◽  
Author(s):  
Karen M. Olsen ◽  
Arne L. Kalleberg
Keyword(s):  
United States ◽  
Public Sector ◽  
The United States ◽  
Institutional Factors ◽  
Temporary Workers ◽  
The Public ◽  
Work Arrangements ◽  
Standard Work ◽  
The Us ◽  
Hiring And Firing

This article examines organizations’ use of non-standard work arrangements - fixed-term employees hired directly by the organization, workers from temporary help agencies (THA), and contractors - in the United States and Norway. Our analysis is based on information obtained from surveys of 802 establishments in the US and 2130 in Norway. We find that Norwegian establishments make greater use of non-standard arrangements than the US establishments; we argue that this is due in part to the greater overall restrictive labour market regulations on hiring and firing regular workers, and greater demand for temporary labour resulting from generous access to leaves of absence, in Norway. We also find that certain institutional factors have a similar impact in both countries. First, establishments in the public sector are more likely to use direct-hired temporary workers and less apt to use contractors and THAs; this pattern is particularly striking in Norway, but is also evident in the United States. Second, highly unionized establishments tend to have the lowest use of non-standard arrangements in both countries.

Ideological parlances on right-wing media in Britain and Finland

2020 ◽  
Vol 5 (2) ◽  
pp. 173-190 ◽  
Author(s):  
Salla Tuomola
Keyword(s):  
United States ◽  
Comparative Study ◽  
Liberal Democracy ◽  
World View ◽  
The United States ◽  
Research Data ◽  
Right Wing ◽  
The Us ◽  
Similarities And Differences ◽  
The Comparative Study

One of the main themes of alternative right-wing media is a strong anti-immigrant approach, which has allegedly intensified a radical and polarized world-view throughout Europe and the United States. In this article, by comparing two right-wing news sites, I examine whether commonalities in their reporting can be discerned at a transnational level. The focus is on the US-based Breitbart London and the Finnish-language MV-lehti, both founded in 2014. The comparative study approaches the research data by utilizing the method of discourse narratology to examine the similarities and differences between the two in terms of their ideological parlances. The results show that there are indisputable commonalities, with parlances that seek to undermine liberal democracy as an outspoken opponent to strengthen the homogeneous battlefront. Accordingly, right-wing news sites in Europe adhere to the shared ideology, leaning on a strong confrontation between western and Islamic countries.

International Migration as an Issue on Today's Inter-American Agenda

1994 ◽  
Vol 36 (3) ◽  
pp. 93-110 ◽  
Author(s):  
Christopher Mitchell
Keyword(s):  
United States ◽  
International Migration ◽  
The United States ◽  
Western Hemisphere ◽  
Labor Migrants ◽  
The Public ◽  
High Profile ◽  
The Us ◽  
Key Factor ◽  
The One

As a frequent concern both of governments and of the public at large in Western Hemisphere nations, international migration is now more prominent than at any time since 1980. The episodic flow of seaborne refugees from Haiti since 1991 has been a key factor in spurring the inter-American community to oppose Haiti's military rulers. The flotilla of rafts leaving Cuba since early August 1994 has engendered high-profile negotiations on migration between Washington and Havana. The stream of undocumented labor migrants from Mexico to the United States has regained momentum since the late 1980s and is encountering increased public criticism, especially in the western United States.Underlying these instances of political tension is a strong, and only partially-met, demand for migration to the United States from parts of Latin America and the Caribbean on the one hand, and a growing anxiety in the US to “control the nation's borders” on the other.

Management consultants and the United States’ public sector

2013 ◽  
Vol 15 (3) ◽  
pp. 381-399 ◽  
Author(s):  
Bessma Momani
Keyword(s):  
United States ◽  
Public Sector ◽  
The United States ◽  
Public Agencies ◽  
The Public ◽  
Management Consultants ◽  
Management Consultant ◽  
The Us ◽  
Strategic Advice ◽  
Different Levels

Management consultants provide strategic advice to public sector agencies and departments throughout the US, contributing to what some scholars call the “hollowing out of the state.” What ideational frameworks underlie these public -private relationships? Findings from a survey of management consultant show that they believe that they are contracted because they provide knowledge that is unavailable inside the public sector and that their ideas are more innovative. This study helps to explain management consultants’ perceptions of their services contracted by US public sector. By gauging the perspectives of management consultants, this research will potentially help academics and practitioners to better understand public agencies’ contracting of management consultants. This article provides preliminary steps towards better understanding and analyzing the use of management consultants by different levels of the US public sector.

scholarly journals The "coming day" of digital government in the United States: a strategy for artificial intelligence

2020 ◽  
Vol 8 (1 SI) ◽  
pp. 103-106
Author(s):  
Oleksii Onufriienko
Keyword(s):  
Artificial Intelligence ◽  
United States ◽  
Public Administration ◽  
Department Of Defense ◽  
Pilot Project ◽  
The United States ◽  
Digital Government ◽  
Public Governance ◽  
The Public ◽  
The Us

The US Department of Defense Artificial Intelligence Strategy (2018) as a pilot project of promising e-modernization of the public sector of this country is analyzed, its place among other initiatives on digitalization of public administration of the current US Presidential Administration is determined, its specific public-administrative logic is clarified. the specifics of this project through the prism of the tasks of modernization of public governance in transforming societies.

scholarly journals Revealing public opinion towards COVID-19 vaccines using Twitter data in the United States: a spatiotemporal perspective

2021 ◽  
Author(s):  
Tao Hu ◽  
Siqin Wang ◽  
Wei Luo ◽  
Yingwei Yan ◽  
Mengxi Zhang ◽  
...  
Keyword(s):  
Public Health ◽  
United States ◽  
Public Opinion ◽  
Public Attitudes ◽  
The United States ◽  
The Public ◽  
Public Sentiment ◽  
Spatiotemporal Trends ◽  
The Us ◽  
Key Events

Background: The COVID-19 pandemic has imposed a large, initially uncontrollable, public health crisis both in the United States (US) and across the world, with experts looking to vaccines as the ultimate mechanism of defense. The development and deployment of COVID-19 vaccines have been rapidly advancing via global efforts. Hence, it is crucial for governments, public health officials, and policy makers to understand public attitudes and opinions towards vaccines, such that effective interventions and educational campaigns can be designed to promote vaccine acceptance. Objective: The aim of this study is to investigate public opinion and perception on COVID-19 vaccines by investigating the spatiotemporal trends of their sentiment and emotion towards vaccines, as well as how such trends relate to popular topics on Twitter in the US. Methods: We collected over 300,000 geotagged tweets in the US from March 1, 2020 to February 28, 2021. We examined the spatiotemporal patterns of public sentiment and emotion over time at both national and state scales and identified three phases along the pandemic timeline with the significant changes of public sentiment and emotion. We further linked the changes to eleven key events and major topics as the potential drivers to induce such changes via cloud mapping of keywords and topic modeling. Results: An increasing trend of positive sentiment in parallel with the decrease of negative sentiment are generally observed in most states, reflecting the rising confidence and anticipation of the public towards COVID-19 vaccines. The overall tendency of the eight types of emotion implies the trustiness and anticipation of the public to vaccination, accompanied by the mixture of fear, sadness and anger. Critical social/international events and/or the announcements of political leaders and authorities may have potential impacts on the public opinion on vaccines. These factors, along with important topics and manual reading of popular posts on eleven key events, help identify underlying themes and validate insights from the analysis. Conclusions: The analyses of near real-time social media big data benefit public health authorities by enabling them to monitor public attitudes and opinions towards vaccine-related information in a geo-aware manner, address the concerns of vaccine skeptics and promote the confidence of individuals within a certain region or community, towards vaccines.

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