In a recent Tax Notes article, Shay argued that Treasury could write regulations to reduce the tax incentives for U.S. corporations to expatriate. Rosenthal agrees with Shay and analyzes the legal support for regulations under section 385.
This Tax Fact documents the increasing share of flow-through business income as a percentage of adjusted gross income (AGI) reported on individual income tax returns. In 2012, net income from sole proprietorships, partnerships, and S corporations totaled nearly $840 billion and accounted for...
Recently, there has been a spate of corporate inversions, where U.S. multinational corporations have combined with foreign companies, arranging their corporate structure to locate the residence of the resulting corporation in a foreign country with an attractive corporate tax climate. This paper...
In a contribution to the Wall Street Journals MarketWatch Inc., Eric Toder and Alan Viard argue that recent highly publicized tax avoidance transactions by U.S. corporations reflect basic flaws in how we tax the income of multinational corporations, and that proposed reforms that maintain...
In a contribution to The Wall Street Journal's MarketWatch, Eric Toder explains why corporations expatriate from the United States and argues that they will continue to do so until Congress addresses the fundamental flaws in the corporate income tax. He then provides some possible solutions to...
On February 28, 2014, the Urban Institute hosted an invitational conference on what policymakers in the United States can learn from the experience of other countries with territorial systems for taxing the income of their multinational corporations. Participants included academic experts,...
A carbon tax is a promising tool for discouraging the greenhouse gas emissions that cause climate change. In principle, a well-designed tax could reduce the risk of climate change, minimize the cost of emissions reductions, encourage innovation in low-carbon technologies, and raise new public...
In testimony before the House Small Business Committee, Donald Marron examines how tax policy affects small business. Complying with the tax code places a disproportionate burden on small businesses. On the other hand, small businesses are more likely to underpay their taxes, sometimes...
A corporate income tax can play a useful role by preventing shareholders from deferring tax on retained corporate profits. The current U.S. corporate income tax is deeply flawed, however, because it relies on definitions of corporate residence and income sourcing that corporations can easily...
This paper documents the increased role of pass-through entities and the associated decline in use of the taxable corporate form since the Tax Reform Act of 1986 (TRA86) and discusses implications for the design of tax policy. We show how significant reductions in the corporate tax rate, absent...
Professor Shay Got It Right: Treasury Can Slow Inversions
In a recent Tax Notes article, Shay argued that Treasury could write regulations to reduce the tax incentives for U.S. corporations to expatriate. Rosenthal agrees with Shay and analyzes the legal support for regulations under section 385.
Flow-Through Business Income as a Share of AGI
This Tax Fact documents the increasing share of flow-through business income as a percentage of adjusted gross income (AGI) reported on individual income tax returns. In 2012, net income from sole proprietorships, partnerships, and S corporations totaled nearly $840 billion and accounted for...
Corporate Inversions
Recently, there has been a spate of corporate inversions, where U.S. multinational corporations have combined with foreign companies, arranging their corporate structure to locate the residence of the resulting corporation in a foreign country with an attractive corporate tax climate. This paper...
Corporate Tax is Broken and Needs Major Surgery
In a contribution to the Wall Street Journals MarketWatch Inc., Eric Toder and Alan Viard argue that recent highly publicized tax avoidance transactions by U.S. corporations reflect basic flaws in how we tax the income of multinational corporations, and that proposed reforms that maintain...
How To Stop Corporations From Fleeing U.S. Tax Laws
In a contribution to The Wall Street Journal's MarketWatch, Eric Toder explains why corporations expatriate from the United States and argues that they will continue to do so until Congress addresses the fundamental flaws in the corporate income tax. He then provides some possible solutions to...
Review of Conference on What the United States Can Learn From the Experience of Countries with Territorial Tax Systems
On February 28, 2014, the Urban Institute hosted an invitational conference on what policymakers in the United States can learn from the experience of other countries with territorial systems for taxing the income of their multinational corporations. Participants included academic experts,...
Tax Policy Issues in Designing a Carbon Tax
A carbon tax is a promising tool for discouraging the greenhouse gas emissions that cause climate change. In principle, a well-designed tax could reduce the risk of climate change, minimize the cost of emissions reductions, encourage innovation in low-carbon technologies, and raise new public...
Tax Issues Facing Small Business
In testimony before the House Small Business Committee, Donald Marron examines how tax policy affects small business. Complying with the tax code places a disproportionate burden on small businesses. On the other hand, small businesses are more likely to underpay their taxes, sometimes...
Major Surgery Needed: A Call for Structural Reform of the US Corporate Income Tax
A corporate income tax can play a useful role by preventing shareholders from deferring tax on retained corporate profits. The current U.S. corporate income tax is deeply flawed, however, because it relies on definitions of corporate residence and income sourcing that corporations can easily...
Changes in the Organization of Business Activity and Implications for Tax Reform
This paper documents the increased role of pass-through entities and the associated decline in use of the taxable corporate form since the Tax Reform Act of 1986 (TRA86) and discusses implications for the design of tax policy. We show how significant reductions in the corporate tax rate, absent...