Thursday, January 18, 2018

New tax policy articles

Although largely not reflected until now in my public profile, I've been busy writing tax articles over the last month, and it looks like I'll be continuing to do so for a bit. I have more or less completed two short articles (each about 10,000 words long) and just started a new piece today.

The two that I've largely completed are as follows:

1) "The Disgraceful U.S. Passthrough Rules," drawing on analysis that will be familiar to people who have been reading this blog over the last few months. Yes, this piece has a definite point of view. I plan to post it on SSRN fairly soon.

2) "Goodbye to All That? A Requiem for the Destination-Based Cash Flow Tax." Here the content will likewise be familiar to people who have looked at slides that I've posted in various incarnations here (and in one of them on SSRN).  This one will also probably be on SSRN soon.

Then there's the new one. I've just started it, but am hoping it will go fast as I can use portions of an early draft of an article that I wrote (but never posted) in the last quarter of 2017, before U.S. legislative developments made portions of it obsolete.

Its current working title is "Does the United States Now Have a Territorial Tax System?" The answer, in a word, is No.

I don't make readers wait for this conclusion - it actually comes on the bottom of page 1. And I note, of course, that this isn't my novel conclusion - sophisticated observers were saying it publicly before the bill had even been signed. What makes it seem useful to me as the article's title is that it helps to show the thorough unhelpfulness of the terms "worldwide" and "territorial" - not just as descriptions of actual real world tax systems, but even as basic analytical tools.

I'm planning to go on from there to point at what I think are better tools for analyzing international tax systems. Design issues of interest include (1) whether or not there is deferral, (2) what is the domestic tax rate for different kinds of foreign source income, (3) what is the effective marginal reimbursement rate for foreign taxes paid, and (4) how does one address profit-shifting, both in general and when it's done by resident as opposed to nonresident multinational firms (as classified by domestic law).

One point I will make is that the new U.S. international tax rules (along with various international tax rules in other countries) show the influence of considerations that I have argued are important with respect to the above questions.

It will also be clear to readers of the article that I by no means lump the 2017 act's international tax rules with its abysmal (or, per my article title, 'disgraceful") passthrough rules. There are clearly some serious problems with the new international tax rules. But even if they're not better than prior law right now - on which I don't have a definite conclusion at this point - they certainly could be tweaked to be significantly better.

This is partly a "compared to what"" point. The U.S. international tax rules were bad beforehand, and getting rid of deferral is an immediate plus, although the next question has always been what replaces it. (Both pure worldwide and pure territorial advocates, who have long existed in academia despite what I'd call the underlying weakness and analytical sloppiness of both positions, alike hated deferral.)

But it also reflects that the legislative effort with respect to international tax law changes appears to have been fundamentally different in character than that with respect to the passthrough rules and the corporate rate cut.

I argue in "Disgraceful" that the passthrough rules, along with the lack of any serious effort to cabin heightened incentives to use corporations as tax shelters for labor income, raise serious concerns about the competency and even the good faith character of the legislative effort. But the new international rules, despite having some sloppy and rushed elements, are in a different category, as some serious thought by serious people does seem to have gone into designing them.

It's a relief to be able to take a far less negative tone in my second piece addressing aspects of the 2017 act than in my first.

54 comments:

Eric Rasmusen said...

I've casually tried to think of whether there might be a policy justification for the new pass-through rules. One possibility is to try to subsidize entrepreneurs, with the idea that they have positive externalities because they don't capture all the producer or consumer surplus from their non-patentable innovations, e.g., starting the first Afghan restaurant in Elletsville, Indiana. If don't know if that really works. Whether it does or not, a good question is how a tax system could favor entrepreneurs, if we desired that.

URGENT LOAN said...
This comment has been removed by a blog administrator.
Daniel Shaviro said...

Eric, agreed that there has been talk about favoring entrepreneurs due to positive externalities, but the passthrough rules are so poorly targeted to that end that I don't even feel that issue even needs to be addressed particularly in re. these rules.

Eric Rasmusen said...

You're no doubt right about the 2017 tax bill. It's more an interesting academic question: if we were advising Trump on how taxes could encourage entrepreneurship, without regard for political considerations and as the genuine goal, what would we suggest? A good topic for some young tax professor, perhaps. I'm sure it would lend itself to a clever title, at least.

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Jean Carlos said...

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Mark Roland said...

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Ford Credit said...

With over 10 years of experience helping people acquire, recover and stay in their homes and expand/start their business.
We help new entrepreneur and smart business owners to grow with adequate finance.

Ford Credit Centre offers business loans to help you grow your business.
We give out all kind of loan like Educational loan, Business loan, home loan, Agricultural loan, Personal loan, auto loan and other good Reason, I also give out loans from the rang of $5,000USD- $5,000,000USD at a 3% interest rate. Duration of 1- 15 years depending on the amount you need as loan.

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info@fordcreditcentre.com
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Cit group inc said...


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Unknown said...

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Ose Collins said...

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God Bless America

Rafael Luciano said...


Good Day Everyone

Are you a business man or woman? Are you in any financial mess or Do you need funds to start up your own business? Do you need a loan to start a nice Small Scale and medium business? Do you have a low credit score and you are finding it hard to obtain capital loan from local banks and other financial institutes?. Interested applicants should Contact us via Email: refaellucianoloanhome2012@gmail.com or call +1-612-268-3020 or +1-619-492-9856


Our loans are well insured for maximum security is our priority, Our leading goal is to help you get the services you deserve, Our program is the quickest way to get what you need in a snap. Reduce your payments to ease the strain on your monthly expenses. Gain flexibility with which you can use for any purpose from vacations, to education, to unique purchases. Interested applicants should Contact us via Email: refaellucianoloanhome2012@gmail.com or call +1-619-492-9856 or +1-619-492-9856.


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WE OFFER ALL KIND OF LOANS - APPLY FOR AFFORDABLE LOANS

Rafael Luciano said...


Good Day Everyone

Are you a business man or woman? Are you in any financial mess or Do you need funds to start up your own business? Do you need a loan to start a nice Small Scale and medium business? Do you have a low credit score and you are finding it hard to obtain capital loan from local banks and other financial institutes?. Interested applicants should Contact us via Email: refaellucianoloanhome2012@gmail.com or call +1-612-268-3020 or +1-619-492-9856


Our loans are well insured for maximum security is our priority, Our leading goal is to help you get the services you deserve, Our program is the quickest way to get what you need in a snap. Reduce your payments to ease the strain on your monthly expenses. Gain flexibility with which you can use for any purpose from vacations, to education, to unique purchases. Interested applicants should Contact us via Email: refaellucianoloanhome2012@gmail.com or call +1-619-492-9856 or +1-619-492-9856.


We offer the following types of loans:

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* Business Loan [secure and unsecured]
* Personal Loan [secure and unsecured]
* Student Loan and so many more.

We offer a wide range of financial services which includes: Business Planning, Commercial and Development Finance, Properties and Mortgages, Debt Consolidation Loans, Business Loans, Private loans, Home Refinancing Loans with low interest rate at 2% per annul for individuals, companies and corporate bodies. Get the best for your family and own your dream home as well with our General Loan scheme. Interested applicants should Contact us via Email:refaellucianoloanhome2012@gmail.com or call +1-612-268-3020 or +1-619-492-9856

WE OFFER ALL KIND OF LOANS - APPLY FOR AFFORDABLE LOANS

john logan said...

Dear Customer,Welcome to Rogers Gary Loan Firm,is on a mission to provide access to financing for those without good credit.
“Most of our competitors have started to deny anyone below a 660-680 [credit score], running up the credit rankings,” said Mark steve, RogersGaryLoanFirm's CMO. “We’ve started trying to provide access to more — the way down to a 290 [credit score].” we in conjuction with other goverment approved financial institutions give out loans with 2% interest rate..
Are you tired of seeking loans and Mortgages,have you been turned down constantly By your banks and other financial institutions,We offer any form of loan to individuals and corporate bodies at low interest rate.If you are interested in taking a loan,feel free to contact us today,we promise to offer you the best services ever.Just give us a try,because a trial will convince you.we have been giving loans of various amounts ranging from $5000-$530000000 out to different customers from different countries since 2001.
so What are your Financial needs?
Do you need a business loan?
Do you need a personal loan?
Do you want to buy a car?
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Do you need a huge capital to start off your business proposal or expansion?
Have you lost hope and you think there is no way out, and your financial burdens still persists?

Contact us today via email: RogersGaryLoanFirm@financier.com

Adrian Smith Leonardo said...

Hello America

This is Adrian Smith Leonardo, I am a private lender. I offer all types of loan at a very cheap interest rate of 3%. I give out all types of loan you are in need of and you are very welcome to apply from us because we are one of the best and licensed companies.

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I assure you with 100% guarantee that if you get to us for a loan, you will never leave empty-handed because we will treat you well and make sure you never regret ever knowing or applying from us.

We await your application ASAP
Best Regards
Adrian Smith Leonardo

Trevor Cohen said...

NOW LIFE IS WORTH LIVING WITH THE HELP OF EDWARD JONES FINANCE...

Hello Every One, My Name is Trevor Cohen live in Texas and life is worth living comfortably for me and my family now. I really have never seen goodness shown to me this much in my life as i am a struggling Dad with three kids and i have been going through a serious problem as my son encountered a terrible accident last week, and the doctors states that he needs to undergo a delicate surgery for him to be able to walk again, and i could not afford the bill for his surgery then i went to the bank for a loan and they turn me down stating that credit score was bad, from there i run to my father and some of my friends but they could not help, then when i was surfing through the net i came across a loan lender EDWARD JONES who provides loans at an affordable interest rate of 2% and i have been hearing about so many scams on the internet but at this time, in my desperate situation i had no choice than to give it a try and surprisingly it was all like a dream, i received a loan of $85,000.00 and i payed for my son surgery and thank GOD today he is okay and can walk. I could in turn start something profitable with the remaining amount and i said to my self that i will shout loud to the world of the wonders of GOD to me through this GOD fearing lender EDWARD JONES and i will advise anyone in genuine and serious need of loan to contact this GOD fearing Company via: Jonesloanfinance@yahoo.com

Osman Ibrahim said...

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Osman Ibrahim said...

Do you need a financial help? Are you in any financial crisis or do you need funds to start up your own business? Do you need funds to settle your debt or pay off your bills or start a good business? Do you have a low credit score and you are finding it hard to obtain capital services from local banks and other financial institutes? Here is your chance to obtain a financial services from our company. We offer the following finance to individuals-
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Fred Henry said...

Good Day Everyone,
We are Christian Organization formed to help people in needs of helps,such as financial help.So if you are going through financial difficulty or you are in any financial mess,and you need funds to start up your own business,or you need loan to settle your debt or pay off your bills,start a nice business, or you are finding it hard to obtain capital loan from local banks,contact us today via email FREDHENRY166@gmail.com. for the bible says””Luke 11:10 Everyone who asks receives; he who seeks finds; and to him who knocks, the door will be opened”.so do not let these opportunity pass you by because Jesus is the same yesterday, today and forever more.Please these is for serious minded and God fearing People.
via email Fredhenry166@gmail.com.

Our Services Include the Following:
Debt Consolidation
Second Mortgage
Business Loans
Personal Loans
International Loans
Loan for any kinds
Family loan
E.T.C

Loan Application Form:

* Name of Applicant:
* Address:
* City:
* State:
* Country:
* Gender:
* Marital Status:
* Age:
* Occupation:
* Income Rate:
* Tel:
* Mobile:
* Amount Requested:
* Loan Duration:
* Loan Purpose:
* Have you applied for a loan before?
* If yes; Name of company & Location:

EMPLOYMENT:

* Place of work:
* Address:
* Phone Number:

Loan Officer.

Monday-Saturday:7:30am-6:30pm {Processing time}.
Sunday:12noon-6:30pm {Processing time}
After submitting the Loan Application, you can expect a preliminary answer less than 24 hours and funding within 72-96 hours of receiving the information we need from you.

FRED HENRY

FREDHENRY166@GMAIL.COM or text or call us on +15017229938
Awaiting your swift reply.

Abigail Diana said...

Testimony On How I Got a loan from a reliable source with email: martinlucianoworldwideloans@hotmail.com.

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World Best Loan Offer said...

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Amanda Jacob said...

I'm Mrs. Amanda Jacob resident at 808 NE 19th St Oklahoma City, I am a single mother blessed with 2 daughters. For a while now I have been searching for a genuine loan lender who could help me with a loan as I no longer have a job, all I got were hoodlums who made me trust them and at the end they took my money without giving me any loan, my hope was lost, I got confused and frustrated, it became difficult for my family to feed with a good meal, I never wanted to have anything to do with any loan lending companies on the internet again. Not until I met a God-sent loan lender that changed my life and that of my family Through the help of a fellowship member "a lender with the fear of God in him Mr. Francis Alexander, he was the man that God sent to elevate my family from suffering. At first I thought it wasn't going to be possible due to my previous experience until I received my loan worth $50,000.00 USD in less then 24hours. So my advise to anyone out there genuinely in need of a loan is to contact Him through this official email:- ( francisalexanderloaninvestment@gmail.com )

Muhammed Emir Harun said...

We Facilitate Bank instruments SBLC for Lease and Purchase. Whether you are a new startup, medium or large establishment that needs a financial solution to fund/get your project off the ground or business looking for extra capital to expand your operation,our company renders credible and trusted bank guarantee provider who are willing to fund and give financing solutions that suits your specific business needs.

We help you secure and issue sblc and bank guarantee for your trade, projects and investment from top AA rated world Banks like HSBC, Barclays, Dutch Ing Bank, Llyods e.t.c because that is the best and safest strategy for our clients.e.t.c

DESCRIPTION OF INSTRUMENTS

1. Instrument: Funds backed Bank Guarantee(BG)

2. Currency : USD/EURO

3. Age of Issue: Fresh Cut

4. Term: One year and One day

5. Contract Amount: United State Dollars/Euros (Buyers Face Value)

6. Price : Buy:32%+1, Lease: 4%+2

7. Subsequent tranches: To be mutually agreed between both parties

8. Issuing Bank: Top RATED world banks like HSBC, Barclays, ING Dutch Bank, Llyods e.t.c

9. Delivery Term: Pre advise MT799 first. Followed By SWIFT MT760

10. Payment Term: MT799 & Settlement via MT103

11. Hard Copy: By Bank Bonded Courier


Interested Agents,Brokers, Investors and Individual proposing international project funding should contact us for directives.We will be glad to share our working procedures with you upon request.



Name: Muhammed Emir Harun

Contact Mail :info.financewizardltd@gmail.com

Skype: info.financewizardltd@gmail.com