Download e-book for iPad: Corporate Tax Shelters in a Global Economy: Why they are a by Daniels N. Shaviro

By Daniels N. Shaviro

ISBN-10: 0844771821

ISBN-13: 9780844771823

This quantity explores the motives and prices of tax avoidance and gives an invaluable advisor to the major conceptual concerns that has to be addressed with the intention to layout a really powerful tax reform.

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Read or Download Corporate Tax Shelters in a Global Economy: Why they are a Problem and What We Can do About it (AEI Studies on Tax Reform) PDF

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Additional info for Corporate Tax Shelters in a Global Economy: Why they are a Problem and What We Can do About it (AEI Studies on Tax Reform)

Sample text

It is, after all, just a semantic issue. And, perhaps the salience of giving the name arbitrage to these instances of clever legal jujitsu is worth the risk of confusion. Yet, one should understand that the sense of semantic inconsistency that underlies the term bears little direct relationship to the reasons why we might be concerned, from a national or worldwide welfare standpoint, about the transactions so described. From a welfare or efficiency standpoint, the main reason for concern about cross-border tax arbitrages (to abandon further quibbling about the name, simply because it has gained such wide acceptance) is that they involve preferential worldwide tax treatment.

S. groups. The result of this double deduction is that an amount of the overall worldwide group’s income equal to the DRC’s loss is taxed nowhere. 11 At present, therefore, the tax losses of DRCs are allowable against consolidated group income in neither the United States nor the United Kingdom. Double-Dip Leases. A similar tax planning idea takes advantage of disparities between countries’ rules for determining who gets depreciation deductions. Suppose that legal title to an airplane is held by a French taxpayer, but beneficial economic ownership goes to an American taxpayer under a long-term lease.

S. tax benefits to taxpayers engaging in certain of these transactions. 3 Under the George W. Bush administration, the Treasury Department has seemed generally less eager to proceed in this area, but it has not MORE REVENUES, LESS DISTORTION? S. S. S. tax results, standing alone, would have been unobjectionable. Commentators sometimes misconstrue the Treasury’s policy concern as based either on the belief that “we . . have a monopoly on correctness”6 or on a perverse preoccupation with other countries’ totally separate tax affairs.

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Corporate Tax Shelters in a Global Economy: Why they are a Problem and What We Can do About it (AEI Studies on Tax Reform) by Daniels N. Shaviro


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