References
for: Gio Wiederhold:
Valuing
Intellectual Capital, Multinationals and Taxhavens
Springer Verlag
2013
Entries marked † were used for [W:06] . Transcription into the spreadsheet for VIC are marked [xls/worksheet]. Shaded text is to be omitted in publication, but helpful for search or as an aide de memoire. I am dding {chapter.section} references. The notation [ACM} indicates its use in an ACM blog.
[Aaron:13B]
Henry J. Aaron: Tax Reform? Between a Rock and a Hard Place; Huffington Post,
Brookings, 15 Jan. 2013. The 1986 reforms shifted $1T (adjusted) from
individuals to Corportations over 10 years. Mobility of capital and the
proliferation of multinatinal companies prevents such a solution now. Must
raise personal income tax.{VIC Ch10.7.4}
[Aaron:13G]
Henry J. Aaron: You Get What You Pay For: Lessons From the IRS Scandal; Brookings,
31 May 2013. Only 1% of returns is audited. $450B is
uncollected. Each dollar spent auditing yields $8. {VIC Ch8,7.3}
[AbahoonieA:10]‡
Edward Abahoonie and Liah Alfonso: Deferred taxes on foreign earnings: A road
map; Price Waterhouse Coopers (PwC), Dec.2010, updated 2012 www.pwc/us/tax. (with a nice picture of Luzern, Switzerland). {VIC Ch2.6}
Abba:97]†
Wayne Abba: "Earned Value Management: Reconciling Government and
Commercial Practices"; Program Manager, Vol.26, pp.58–69. {VIC Ch8.7.2}
[AbramitzkyB:04] Ran Abramitzky and Fabio Braggion: Malthusian and Neo-Malthusian
Theories; Oxford Encyclopedia of Economic
History, Oxford University Press, 2004. At
Stanford University.{VIC Ch9.4.5}
[Acritas:10]
Rankings of law firms employed for cross-border litigation and deals; BBW
27Sep.2010, p20. {VIC Ch8.7.4}
[ACS360:09]
Financial Accounting Standards Board: Property, Plant, and Equipment;
Accounting Standards Codification 360-10-35-4, Depreciation, Version 3.0, 1
July 2009. Depreciation is a method of allocation, not of valuation.
{VIC Ch3.4}
[Actionaid:11] ActionAid: Addicted to tax havens, the
secret life of the FTSE 100; ActionAid, UK, Oct.2011, http://www.actionaid.org.uk/doc_lib/addicted_to_tax_havens.pdfl. {VIC
Ch8.5.3}
[Adams:97] James D. Adams,
1997. "The Structure of Firm R&D and the Factor Intensity
of Production“; NBER
Working Papers 6099, National Bureau
of Economic Research, Inc.; also Working
Papers 97-15, Center for Economic
Studies, U.S. Census Bureau. {VIC Ch5.7}
[Adams:12]
Scott Adams: Dilbert; Famous Quotes,
Retrieved Jan. 2012. “There are many methods for predicting the future. For
example, you can read horoscopes, tea leaves, tarot cards, or crystal balls.
Collectively, these methods are known as `nutty methods.’ Or you can put
well-researched facts into sophisticated computer models, more commonly
referred to as `a complete waste of time’." {VIC Ch5.1}
[ADLittle:85] ADLittle: Development of a Methodology for Estimating
the Taxpayer Paperwork Burden; IRS, June 1988. Time cost for individual and business
taxpayers $1813M, $3,614M = total 5,427M hours. [xls/irs] {VIC Ch8.2.2}
[AF:04] The
Appraisal Foundation: Uniform Standards
of Professional Appraisal Practice; Standard 9, 2004 Edition. {VIC Ch.3.3}
[AgarwalG:99] Rajshree
Agarwal and Michael Gort: First Mover Advantage and the Speed of Competitive
Entry, 1887-1986; National Bureau of Economic Research (NBER), Sep.1999; SSRN
library http://ssrn.com/abstract=167330. {VIC Ch7.4.1}
[AghionH:94]
Philippe Aghion and Peter Howitt: "Growth and Unemployment“; Review of Economic Studies, Wiley
Blackwell, Vol.61 no.3), pp.477-494, July 1994; CEPR
Discussion Papers 577.
[AGN:08]‡
AGN International: The AGN European Region - 2008 Corporate Tax Survey, 2008
<http://www.agn-europe.org>. Annual surveys of ominal
and effective tax rates.
[Aiken:09] Alex
Aiken: Measure of Software Similarity Software; MOSS software, 2009, <http://www.similix.com>.
{VIC Ch5.1.i}
[Albinus:12]‡
Phil Albinus: Fleeing Dodd-Frank, Hedge Funds Follow the Sun; Advanced Trading, 5 Jan 2012. Taxhavens protect
bonuses. See [Kahn:12] .As of early November, the number of funds located in Malta
had grown to more than 500 with 8 billion euros ($10.7 billion) under
management from 165 funds with less than 5 billion euros under management in
2006, according to the Malta Financial Services Authority, or MFSA.
[Alistair Alcocks.172
CA
2006, "to promote the success of the company for the
benefit of its members as a whole". It sets out six factors to which a
director must have regards in fulfilling the duty to promote success. These
are: 1. the likely consequences of any decision in the long term, 2.the
interests of the company’s employees, 3.the need to foster the company’s
business relationships with suppliers, customers and others, 4.the impact of
the company’s operations on the community and the environment, 5.the
desirability of the company maintaining a reputation for high standards of
business conduct, and, 6.the need to act fairly as between members of a
company. This represents a considerable departure from the traditional notion
that directors' duties are owed only to the company.
[Alderman:10]
Liz
Alderman:
”In Ireland, Low Corporate Taxes Go
Untouched”; The New York Times, 25 Nov.2010. “The corporate tax
is one of the pillars of Ireland’s economy, because it drives exports and jobs,
and creates tax revenues for the government”; said Paul Duffy, a vice president
at Pfizer in Ireland, one of the biggest multinational employers here. Raising
the tax could scare away companies and “would damage a recovery and our ability
to repay the massive debts we’ve taken on”; he said. /Critics, however, say that in addition to
siphoning business from countries with higher corporate tax rates, some
multinationals operating under Ireland’s tax rules use complicated schemes to
move profits in and out of subsidiaries there. In some cases, that allows them
to lower their effective tax rate, they say. /That has opened Ireland to
criticism from countries like Germany, where Chancellor Angela Merkel
must justify why taxpayers should help pay for another bailout package. The
argument is that Ireland could be collecting more money from the companies it
has lured. /Tax rates have become a contentious issue in Europe, where
governments are competing as never before to lure badly needed foreign
investments as the economic crisis weighs on growth.
[AlmDM:04] James Alm, John
Deskins, And Michael McKee: Tax Evasion and Entrepreneurship: The Effect of
Income reporting Policies on Evasion; 97th
Annual Conference of the National Tax Association, Minneapolis, MN, Nov.2004.
An audit
rate of 10% vs 30% doubles non-compliance.
[Allan:11]
Robert B. Allen (allen@acm.org): Information: A Fundamental Construct; <http://boballen.info/ISS/. The text is still under development , 2011.
[Almeida:04] Aloisio Almeida: Tax Havens:
An Analysis of the OECD Work with Policy Recommendations; Ford School of Public
Policy, Apr.2004. 5 uncooperative jurisdiections: Andorra, Liberia, Liechtenstein, Monaco,
Marshall Islands. Three were removed in
2000: Barbados, Maldives, Tonga, 33 will fix ttransparency.
[alSayigh:78]
Yusif al Sayigh: World Economic Outlook Conf.; Economic Advisor. Arab Fund for
Social and Economic Development, 9-10 Nov 1978. Quotes Arab proverb: "Listen and
you will be very happy, but look and you will be terribly sad". [VIC Ch.NNNNN]
[Alter:11] Jonathan
Alter: Coming Lobbyist Brawl May
(Really) Fix Our Taxes; Bloomberg
Businessweek, 5 Aug 2011. the author of “The
Defining Moment: FDR’s Hundred Days and the Triumph of Hope” . On the supercommittee’s chances.
[AltmanEa:12] Roger Altman,
William Daley, John Podesta, Robert Rubin, Leslie Samuels,Lawrence Summers,
Neera Tanden, and Antonio Weiss with Michael Ettlinger, Seth Hanlon, Michael
Linden: Reforming Our Tax System, Reducing Our Deficit; American Progress, Dec.
2012
[Altshuler:10] Rosanne Altshuler: “Capital income
taxation and progressivity in a global econmy”; Virginia Tax Review, 22 Sep.2010. see [AltshulerHT:10]
[AltshulerACK:08] Rosanne Altshuler, Alan J. Auerbach,
Michael Cooper, and Mathew Knittel: Understanding U.S. Corporate Tax
Losses; NBER Tax Policy and the Economy Conference, Washington, DC, 6.Oct.2008.
Tax
expenditures , Many Graphs. Uses form 1120 data. Cooper and Knittel are
with the Treasury.”...taxpayers can engage in .excessive. or in some other way
unintended use of legal tax provisions to reduce tax liabilities.”
[AltshulerG:01] Rosanne
Altshuler and Harry Grubert: “Where Will They Go if We Go Territorial? Dividend
Exemption and the Foreign Location Decisions of U.S. Multinational
Corporations”; National Tax Journal, Vol.54 No.4, Dec.2001, pp.787-809.
[AltshulerM:96]‡ Rosanne Altshuler and Jack M. Mintz:
“United States Interest-Allocation Rules, Effects and Policy”; in [Slemrod:96]
.
[AltshulerHT:10] Rosanne Altshuler, Benjamin Harris, and Eric Toder: “Capital Income
Taxation and Progressivity in a Global Economy”; Virginia Tax Review, Vol.30, Fall 2010, pp.355-388. Tax gains at 28%
and dividends fully yields $87B to reduce corporate tax from 35% to 26%.
[Amadi:02] Confidence
W. Amadi: Double Taxation of Dividends: A Clarification <http://www.westga.edu/~bquest/2002/double.htm>. “The greatest advantage of the
corporate form of business organization is the limited liability protection accorded
its owners. Taxation of corporate income is the price of that protection. This
price must be worth the benefits since, according to the Internal Revenue
Service (1996), corporations account for less than 20 percent of all U.S.
business firms, but about 90 percent of U.S. business revenues and
approximately 70 percent of U.S. business profits. The benefits of limited
liability independent of those enjoyed by shareholders, the flexibility of
change in ownership, and the immense ability to raise capital are all derived
from the legal entity status accorded corporations by the law. This equal
status requires that corporations pay income taxes.... .
[AmdahlBB:64] Gene M. Amdahl, Gerrit A. Blaauw, and Frederick P.
Brooks jr.: "Architecture of the System/360"; IBM J. R&D, Vol.8 no.2, April 1964, pp.87-101. Allocation of value to three types of development
efforts.
[AmirLS:03] Eli
Amir, Baruch Lev and Theodore Sougiannis:: “Do financial analysts get intangibles?”; European Accounting Review, 2003, pp.635-659.
Deals with
access to intangible info by sector.
[AmrominHLS:05]‡ Gene
Amromin, Paul Harrison, Nellie Liang, and Steve Sharpe: How Did the 2003 Dividend Tax Cut Affect
Stock Prices and Corporate Payout Policy?; Finance and Economics Discussion
Series, Federal Reserve Board, Washington, DC, working paper 57, Sep.2005.
[Anderson:08] Chris
Anderson: “Free! Why $0.00 is the future of business”; Wired
Magazine, Vol.16 no.3, 25
Feb2008,http://www.wired.com/techbiz/it/magazine/16-03/ff_free?currentPage=all.
[Anderson:09] Eric Anderson: Take the Money and Run, Sovereign Wealth
Funds and the Demise of American Prosperity; Praeger Security
International, 2009. Stanford Library
checkout, bought it later. Focus on Souvereign wealth funds, in the city.. Chap
5 has merger rules, Chap 6 on tax 2008 plans [xls/industry]‡
[Anderson:10]‡ David Anderson: Remodeling Pre/Post
Conflict Development Assistance for Weak and Failing States; Entrepreneurship
and Expeditionary Economics, Kauffman, Command and General Staff College Foundation,
2010. , cites [Ketsdever:10]‡
[AndersonC:00] Sarah Anderson
and John Cavenaugh: Top 200: The Rise of Corporate Global Power; Institute for
Policy Studies, 2000. Used wrong metrics
[Woolf:04]
[Andriessen:03]
Daniel
Andriessen: Making Sense of Intellectual
Capital: Designing a Method for the Valuation of Intangibles; Butterworth-Heinemann, Dec. 2003. Ex KPMG author, 25 methods sketched covering Management, human resources,
company performance, accounting, and business
transactions. Methods are critiqued; no quantitative results.
[AndrusP:09] Joseph L.
Andrus and Irving H. Plotkin: PKN Alert United States – Prsident Obama’s
proposal to limit shifting of income through intangible property transfers;
Pricing Knowledge Network, PricewaterhouseCoopers, 22 May 2009. Calls §936(h)(3)(B) a laundry list, but laundry lists
do not have an entry for `other similar items’
[AngusNSW:10] Barbara Angus, ToAndruem
Neubig, Eric Solomon, and Mark Weinberger: “The U.S. International Tax System
at a Crossroads”; Tax Analysts,
E&Y, 2010. Companies will invest if taxed more. Tables of Fortune 500 global
companies. importance of intangibles and services. “Changes to the international tax rules
should not be undertaken piecemeal.”
[AnkenB:11]
F. Anken and J.E. Beasley: Corporate structure optimisation for multinational
companies; Omega, 2011.
[AnsonA:03]
Weston Anson and Chaitali Ahya: How to Make Transfer Pricing Work for IP and
Intangible Assets; Int'l Tax Rev., Vol.1514 (2003-2004) <filed under de Mooij>
[AnsonEa:09]
Tim Anson, Nardi Bree, Carl Dubert, Marty Collins, Tom Quinn, and Greg Libkin:
Outbound Transfer of Foreign Goodwill and Going Concern Value; Journal of
International Taxation; Transfer Pricing Insider, Vol.3 Issue 3,
PricewaterhouseCoopers, Nov. 2009. Comment on [IRS-TAM:09]. The TAM, and similarbObama
administration proposlas, would significantly narrow transferring a business
without paying income tax.
[AntosEa:08] Joseph Antos
et al.: Taking Back Our Fiscal Future; The Brookings Institution and The Heritage
Foundation, 2008, <http://www.brookings.edu/~/media/Files/rc/papers/2008/04_fiscal_future/04_fiscal_future.pdfl> Cut growth of
Social Security, Medicare, and Medicaid.
[AP:11] AP: Western Union to Pay $220M More in IRS Settlement;
Associated Press, Bloomberg Businessweek,
15 Dec.2011.
[Appelbaum:12] Binyamin
Appelbaum: ”Tax Break Increases Deficit, But May Have a Silver Lining”; The New York Times, 3 Feb.2012.
[Applegate:13] Evan
Applegate: “Bid/Ask”; Bloomberg
Businessweek, 27 May 2013, p.65.
[AppleyardFC:06]
Dennis R. Appleyard, Alfred J. Field and Steven L. Cobb: International
Economics; McGraw-Hill Irwin, 2006.
<http://www.irs.gov/businesses/article/0,,id=179270,00.html>. <<add
to chapter 3 workforce>> Starting 1999 to 2006 US company with a
Possessions corporation transfer assets as a non-taxable contribution
(Sect.351) or non-taxable reorganization (sect.361) to a CFH in Bermuda or so.
The Puerto Rico operation becomes a subsidiary of the CFH. A taxpayer may claim that transfers from the § 936 corporation
include
a significant amount of value in the form of workforce-in-place and that such
workforce-in-place is not taxable. Workforce-in-place is properly treated
as an intangible under § 936(h)(3)(B), and is therefore taxable under USC §
367(d). Some taxpayers have argued that the workforce-in-place is a part
of going concern value that transfers tax free to the foreign
corporation. However, to
the extent that workforce-in-place can be identified and valued as a distinct asset,
workforce-in-place should
not be viewed as part of foreign goodwill or going concern
value.
[Argy:06] Victor Argy: The Postware International Money Crisis:
An Analysis; Taylor and Francis, 1981, reprinted 2006 by Routledge. Any changes? Eurodollar reserves in 1976, 222.1B SDR. $485B per Morgan Guarantee
[Arnold
M:93] Brian J. Arnold & Thomas E. McDonnell: Report on the Invitational
Conference on Transfer Pricing: The Allocation of Income and Expenses Among
Countries, 7 Tax Notes International, 1507 , 13 Dec.1993 . use of cost sharing
by oil companies, equal risk.
[ArnoldM:02] B.J. Arnold and, M.J.
McIntyre: International Tax Primer;
Kluwer Law International, 2002.
[Aron:83]†
J.D. Aron: The System Development Process, The Programming Team (Part II);
Addison-Wesley, 1983. The input to software
IP generation, a component of intelectual capital. Coherence and complementarity.
[Arora:13]
Jaime Arora: Negotiating Transfer Pricing Safe Harbors Will Take More Time,
Maruca Says; Tax Notes Today, 5 Jun.2013.
Unclear
that the concept will be effective as long as sometax havens are left.
[Arthur:83]†
Lowell Jay Arthur: Programming Productivity; Chapter 8 on Maintenance,
Wiley, 1983.
[ArthurEa:12]‡
Brian P. Arthur: IRS Issues Final Regulations for Cost Sharing Arrangements;
Baker & McKenzie, 9 Jan 2012. The platform approach to transfer pricing is now
official.
[ASCAP:10] The American Society of Composers, Authors and
Publishers: Customer licensees; ASCAP, 2010, <http://www.ascap.com/licensing/licensingfaq.html>
[AschhoffS:09] Birgit Aschhoff
and Wolfgang Sofka: "Innovation on demand--Can
public procurement drive market success of innovations?“; Research Policy, Elsevier, Vol.38 no.8, Oct.2009. pp.1235-1247.
[Asher:09]‡ Mukul G Asher: Needed, a more
comprehensive approach to tax havens; Daily News
& Analysis (DNA), 9 May 2009. Complete reference
from vaishab.
[Ashley:10]‡ Sophie Ashley: “Ireland increases withholding
tax exemption”; International Tax Review,
01 Nov.2010.
[AshrafG:11]
Quamrul Ashraf and Oded Galor: “Dynamics and Stagnation in the Malthusian Epoch”;
American Economic Review, Vol.101
no.5 Aug.2011. <http://web.williams.edu/Economics/wp/AshrafGalor-Malthus.pdf>,
<http://ideas.repec.org/p/wil/wileco/2010-01.html>
[AtkinsB:13] Ralph Atkins and Alex Barker: “Robin Hodd tax: A long shot”; Financial Times; 20 May 2013. European plans for a financial transaction levy are likely to be diluted.
[Atkinson:11] Robert D. Atkinson: U.S. Corporate Tax Reform:
Groupthink or Rational Debate?; The Information Technology & Innovation
Foundation, Washington DC (ITIF) report,
July 2011, <http://www2.itif.org/files/2011-corporate-tax-reform.pdfl>.
[Atkinson:12]
Robert D. Atkinson: Enough is Enough: Confronting Chinese Innovation
Mercantilism; The Information Technology & Innovation Foundation,
Washington DC (ITIF) report,
28 Feb.2012, <http://www.itif.org/2012-enough-is-enough.pdfl>. Several groups: 1.
hard core base broadeners to lower corp. tax, programatic base brodeners (keep
R&E). 3. Simpler code raising the effective tax, 4. Pragmatic Incentivists
as ITIF view tax code as a tool.
[AtkinsonS:76]
Anthony B. Atkinson and Joseph E. Stiglitz: “The Design of Tax Structure:
Direct versus Indirect Taxation”; Journal
of Public Economics, Vol.6 no.1-2, 1976, p.55-76. Reprinted in Social Justice and Public Policy,
MIT Press, 1983. Parts appeared 1970-1972, Many
hurdles.
[ATRA:13] : American Taxpayer Relief Act; HR-8, 3 Jan 2013.
[
[
[Audretsch:95] David B. Audretsch: Firm profitability,
growth, and innovation; Review of Industrial Organization, Vol.10, no.5, 1995,
pp.579-588. Lag is 4.2 years , leverage for
innovatve industries 2.563, for innovative computer companies 4.525.
[AudretschL:12]
David B. Audretsch and Albert N. Link: “Valuing an Entreprneurial Enterprise”; Small Business Economics, Vol.38 2012,
pp.139-145. Shows that 4 typical methods do not
work. Says he offers a methodology, but only cestimates number of startups.
[Auerbach:99] Alan J. Auerbach: “Measuring
the impact of tax reform”; in [Slemrod:99], p.360
. Making
incremental changes is more effective than grand ones.
[AuerbachF:02] Alan J. Auerbach and Martin Feldstein, eds.: Handbook of Public Economics, Vol.4, North-Holland,
2002.
[Auerbach:06] Alan
Auerbach: Why have Corporate Tax Revenues Declined” Another Look; CESifo workshop, The Future of Capital Income
Taxation, Venice, July 17-18, 2006, updated Dec.2006. Ignores effect of AJCA.
Auerbach:06F] Alan Auerbach: The Future of Capital
income taxation ; 2006 Institute for Fiscal Studies Annual Lecture, Sept 2006. at
the University of California at Berkeley. found that whereas in 1983 financial corporations
accounted for only about 5% of all corporate-tax revenues in America, between
1991 and 2003 they made up roughly a quarter. Kep the Corporate income tax.
[Auerbach:05] Alan
Auerbach: Who Bears the Corporate Tax, A Review of What we Know; NBER’s Tax
Policy and the Economy conference, Sep.2005. Different sizes of corporations,
shareholders, and timing. Refers to Harberger. Consders intangible value, but
at a modest (50%) increment. A corporate tax distorts, is not desirable. Too
much individual capital is tied up in housing.
[AuerbachDS:08]
Alan Auerbach, Michael P. Devereux, and Helen Simpson: “Taxing Corporate Income”; Mirrlees Review, Reforming the Tax
systems for the 21st Century; 2008. Focus on UK. What base, where.
Jerald
D. August: G-20 Finance Ministers
Recently Announce Continuing Efforts Towards Achieving Automatic Information
Exchange; Mondaq, Fox Rothschild, 26
May 2013. Adopt the Mutual Assistance Convention of 1998,
for automatic information exchange, not just TIEAs.?
[Aujean:01] Michel Aujean (chair): Company Taxation in the Internal Market; Commission
of the EC, 23 Oct 2001. Includes problems with Transfer pricing, and intangibles.
[Auletta:09A]
Ken Auletta: “Searching for Trouble, Why Google is on its Guard”; New Yorker Magazine, 12 Oct.2009,
pp.46-56. Abstract or Audio:
[Auletta:09B]
Ken Auletta: Googled; 2009. Expands [Auletta:09A]
On Kindle.
[Austin:08] David
Austin: Effects of Gasoline Prices on Driving Behaviour and Vehicle Markets;
Congressional Budget Office, Congress of the United States, Jan.2008.
[AviYonah:95] Reuven
S. Avi-Yonah: “The Rise and Fall of Arm's Length: A Study in the Evolution of
U.S. International Taxation”; Va. Tax
Rev., Vol.15, 1995, p89.
[AviYonah:02] Reuven S. Avi-Yonah: For Haven's Sake: Reflections on
Inversion Transactions; University of Michigan Law School, Tax Notes,
Vol.95 no.12, June 17, 2002. ??AAAA
[AviYonahC:08]‡
Reuven S. Avi-Yonah and Kimberly Clausing: “Reforming Corporate Taxation in a
Global Economy: A Proposal to Adopt Formulary Apportionment”; in Paths
to Prosperity [FurmanB:08]‡, 2008, pp.319-344, 2008.
[AviYonah:12]‡
Reuven S. Avi-Yonah: Statement to Congress; University of Michigan School of
Law, Permanent Subcommittee on
Investigations, U.S. Congress, 20 Sep.2012. Commensurate, was emphasized in 1986,
ignored again by now. Cost-sharing rules, low payment for R&D, high income
offshore. Split. CFC look-through
regulation misused. Disregarded lower CFCs. Short term loan is only one ploy
for repatriation. Blames IRS rules on RAB, override costsharing agreements,
treat inatngibles properly. MisvaluationDo aawy with look-through rule and
check the box..MS Puerto Rico where US IP rights reside earn on the average
45K/a.
[Avril:11]‡
Hillaire Avril: Africa, Emerging Trend Towards Establishing Offshore Tax
Havens; Interpress Service (IPS), 17 Aug.2011.
[Ayal:75]† Igal Ayal: Simple Models for Monitoring
New Product Performance; Decision Sciences, 1975, Vol.6, pages 221-236. Aggregation and repurchase.
[W:13] Gio Wiederhold
[B&McK:09]
North American Tax Practice Group: Transfer Pricing, Managing Intercompany
Pricing in the 21st Century; Baker & McKenzie, 2009.
[B&McK:11] 2011 Aug.workshop materials in HMAT.references/2011 Aug.workshop materials in HMAT/references/Baker&McKenzie11
[Bachman:10]
Helana Bachman: “Why More U.S. Expatriates Are turning in their Passports; Time Magazine World, 20 March 2010.
[Bachman:12]
Helana Bachman: “Why U.S. Tax evaders Can no Longer Count on Swiss Secrecy; Time Magazine World, 15 March 2012.
[BaerZ:09]
Nikolaus Baer and Robert Zeidman @ Zeidman Consulting: Measuring Software
Evolution with Changing Lines of Code; VIP-CATA
conference 10 April 2009, 24th
International Conference on Computers and Their Applications, New Orleans, LA. Cites
[Wiederhold:2006] .
[BahreeB:12] [xls/taxhavens]
[BajajBN:99] : Mukesh Bajaj, Brian
Becker, and Jonathan Neuberger: Transfer Pricing and Foreign Exchange Risk;
Transfer Pricing Report, Vol.8 no.6, 15
July1999, pp.251-259. Have copy. Hedging, insurance, broaden the interquartile
range to account for risk.
[BajajDFS:01] : Mukesh Bajaj
(Managing Director of Finance and Damages Practice of LECG, LLC), David J.
Denis**, Stephen P. Ferris & Atulya Sarin: Firm Value and Marketability
Discounts; working paper, SSRN. Managing Director of Finance and Damages
Practice of LECG, LLC
[Baker:10]
Raymond Baker: “Transparence First”; The
American Interest, July-Aug.1010.
[Baker:11]
George Baker: “No Death, no taxes, The libertarian futurism of a Silicon Valley
Billionaire”; The New Yorker, 28
Nov.2011. Peter
Thiel’s background, attitudes, and plans.
[BaldwinK:04]
Agglomeration, Integration and Tax Harmonization; European Economic Review,
vol.48 No.1 p-23. In [PalanMC:] .
[BaltagiR:05]
Badi H. Baltagi and Daniel P. Rich:
"Skill-biased technical change in US manufacturing: a
general index approach“; Journal of Econometrics, Elsevier, Vol.126 no.2), pp.549-570, June. 2005; IZA
Discussion Papers 841, Institute for
the Study of Labor (IZA).
[Banks:10] Nancy Turner Banks: AIDS,
Opium, Diamonds, and Empire: The Deadly Virus of International Greed; iUniverse,
Kindle , May 2010
[Banner:80]
Donald W. Banner: "Pricing the Technology"; Domestic & International
Licensing of Technology 1980, T.
Arnold and J.T. McCarthy, Eds., Practi(s/c)ing Law Institute, 1980. Not at SUL. The
source appears to be an annual treatise by an institute within NYU, but is not
now publicly available. ??VVVV
[Baran:6x]
Paul Baran Baran wrote about in the early 60's:
that computer networking would bring about the decline of governments. JM had hoped to ask Kleinrock why it
is that we so rarely hear of Paul Baran ("BEAR-en) NNNN
[Baranson:78] Jack Baranson: Technology and the Multinationals;
Lexington Books, 1978. p. 64. Cited by [Caves:83]‡.
Offshore movement of IP. Have chapter around p. 33; also see p.64.
[Barber:02]
Benjamin R. Barber, A Failure of Democracy, Not
Capitalism; The New York Times, July 29, 2002.
[BarL:10]‡ Michael Bar and Oksana Leukhina: The Role of Mortality in
the Transmission of Knowledge; Journal of Economic
Growth, Vol 15 no.4 Dec.2010. Bar is at SFSU
Historical study of the years of the plague: 1650-1880.
[Barthold:11] Thomas
A. Barthold: Response to Lloyd Doggett, containing revenue estimates for a new
repatriation under IRC 965; Joint Committee on Taxation, Congress of the United
States, 15 April 2011.
[BarIlanS:96]‡ Avner Bar-Ilan and William C. Strange: "Investment Lags"; American Economic Review, American Economic Association, Vol.86 No.3,1996, pp.610-622.
[BarlettS:00] Donald L. Barlett and James B. Steel: The Great American Tax Dodge, How Spiraling
Fraud and Avoidance Are Killing Fairness, Destroying the Income Tax, and
Costing You; Little, Brown, and Co., 2000. Have. Diatribe. Belize IRS staff inadequate
p.21. No resources to chck EITC. p.27 . IRS cannot track extraterritorial
transfers p.55. effect of Vereinsgesetz p67. Few Shjam tranascations get caught
p.73 IRS unable to deal with Internet transactions p89.Domonizing the IRS p119,
Constraints on IRS personnel p.123.audits of HNWI slow p.164.. sales tax p246.
[Barra:98]†
BARRA: United States Equity Version 3 (E3); MSCI, BARRA, Berkeley, CA, 1998.
[Barrett:12]‡
Paul M. Barrett: “White Shoe Blues”; Bloomberg
Businessweek; 23 April, 2012.
[Bartlett:81]‡ Bruce Bartlett: Reaganomics: Supply Side Economics in Action; Arlington House, 1981.
[Bartlett:06]‡ Bruce Bartlett: Impostor: How George W. Bush Bankrupted America and
Betrayed the Reagan Legacy; Doubleday, 2006.
[Bartlett:09]‡ Bruce Bartlett: The New
American Economy, The Failure of Reaganomics and a New Way Forward; Palgrave McMillan, 2009.
[Bartlett:12B] Bruce Bartlett:
The Benefit and the Burden, Tax Reform, Why We Need It
and What It Will Take; Simon and
Schuster, Have. Excellent, covers
all aspects of taxation and the imbalances created. But this three page
proposal at the end has no numbers, exactly what he criticizes others
about. [xls/taxes]
[Bartlett:12G]‡ Bruce Bartlett, GOP: All Talk on Eliminating Tax
Breaks – No Action, Fiscal Times, Aug. 24, 2012, http://www.thefiscaltimes.com/Columns/2012/08/24/GOP-All-Talk-on-Eliminating-Tax-Breaks-No-Action.aspx#page1.
[Bartlett:12T] Bruce Bartlett:
How to Avoid Reinventing
the Wheel on Tax Reform; The New York
Times, 24, 31 Jan. Avoid gimmicks,
and focus on corporate taxation.
[Basili:90]† Victor Basili: "Viewing Maintenance as
Reuse-Oriented Software Development"; IEEE Software, Vol.7 No.1,
Jan.1990, pp.19-25.
[BassettCG:09] Barton W.
Bassett, William F. Colgin jr., and Neal A Gordon: Veritas v. Commiossioner:
Tax Court Decision Exposes Flaws in Common IRS Cost-Sharing Buy-in Theories,
Morgan Lewios Tax Practice, Palo Alto, 16 dec. 2009. IRS includes workforce in place,
goodwill, Going-concern value. Shows unpreparedness of IRS expert witness
[Bastiat:xx]
Frederick Bastiat: What is seen and What is Not seen; Essays in The economics
of Freedom, What your Professors won’t tell you; have on Kindle
[BathalaMR:84]
C.T. Bathala, K.P. Moon, and R.P. Ramesh: “Managerial Ownership, Debt Policy,
and the Impact of Institutional Holdings: An Agency Perspective”; Financial
Management, Vol.23 no.3, Autumn 1994, pp 38-50. . Percentage of
revenue spent on R&D and advertising
= 3.5 percent in cross-section
[Basse:11] Søren Hetland Basse: Science History and The
Future; Royal Danish Library reg.1992,
translated and updated 11 Feb.2011, <http://unifiedscience.blogspot.com/>.
Developing
countries
[BassL:83]
Frank M. Bass and Robert P. Leone: Temporal
Aggregation, the Data Interval Bias, and Empirical Estimation of Bimonthly
Relations from Annual Data; Management
Science, Vol.29 No.1, Jan.1983, p1-11.
Advertisement
life is equal to product replacement interval (p.7, quoted by [Berndt:91]
[Batelle:73]†
Batelle Laboratories: Evaluation of the Implementation of a Medical Information
System in A general community Hospital"; report on a study commissioned by
NCHSRD, DHS, 1973.
[
[Baumgarten:09]
Daniel Baumgarten "International Outsourcing, the Nature of Tasks, and Occupational
Stability – Empirical Evidence for Germany“; Ruhr
Economic Papers 0108,
Rheinisch-Westfälisches Institut für Wirtschaftsforschung, Ruhr-Universität
Bochum, Universität Dortmund, Universität Duisburg-Essen, 2009.
[Baumol:72]‡ William J. American Economic Review, Vol.62 no.3, Jun.1972, pp.307–322, JSTOR 1803378
Banco Nacional de Comercio
Exterior, 2009, <http://www.bancomext-mtl.com/invest/vox128.htm.
[BE:02]
INVERinvest: Belgian tax Shelter for Belgian Films; Loi Programme 2/08/2002, le
gouvernement belge,
<http://www.inverinvest.be/pages/Le-produit-Tax-Shelter.fr.php. Ce mécanisme a
déjà conquis plus de 800 sociétés belges et
plus de 200.000.000€ d'Euros de fonds ont déjà été levés Tax Shelter
depuis la création du mécanisme.
, <http://www.bea.gov/national/pdfl>/nipaguid.pdfl>.
<http://www.bea.gov/international/di1usdop.htm.
[BEA:11S]‡ BEA: statistical tables, as Tables 13, Employment of Nonbank Foreign Affiliates, Country by Industry of Affiliate, 1992 <http://www.bea.gov/scb/account_articles/international/0395iid/table13.htm.
[Beck:99]†
Kent Beck: Extreme Programming Explained: Embrace Change;
Addison-Wesley, 1999.
[Bekkelund:11] Kim-Joar Bekkelund: Crowdsourced
Customer Acquisition: A Conceptual Framework for "Freemium and
Propositions for Future Research;Master's Thesis,
Norwegian University of Science and Technology, Jun. 2011. from Sonny Chan CS207.
[Bell:09a] Kay Bell: Tempting the Tax
Auditor; Bankrate.com, 2009.
[Bell:09b] Kay Bell: Taxpayer Advocate calls for help; Bankrate.com, 9 Jan 2009. Shulman, olson.
[Bell:11] Kevin A. Bell: Transfer Pricing: IRS to Elevate
Transfer Pricing Function, Move Directly Under Deputy Commissioner; BNA Daily Tax Report, Dec.16, 2011.
[Bell:12] Kay Bell: Taxpayer Advocate calls for help; Bankrate.com, 13 Aug. 2009.
[Bellew:1734]
Frank Bellew: Joe Miller’s Jests, with Copious Additions; T. Read, London,
1734; on Google eBooks, 2010.
[Benioff:02]†
Marc Benioff: "Salesforce.com: What Economic Downturn?; Destination CRM,
www.destinationcrm.com/articles/default.asp?ArticleID=391, January 2002.
[Bennett:11] Alison Bennett: Tax Regulations: 'Mayo' Ruling Raises
Bar for Challenges To Tax Regulations, Practitioners Say; BNA Daily Tax Report, 14 Feb.2011.
[Bennett:11D]
Alison Bennett: IRS Unveils Bonus
Depreciation Guidance Giving 2010 Election Flexibility; BNA Software, 30 March 2011. Revenue Procedure 2011-26, IRS offered guidance under
the Small Business Jobs Act of 2010 (Pub. L. No.111-240), and the Tax Relief,
Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (Pub. L. No.111-312).
In general, the two laws
extend the time that taxpayers already could take 50 percent bonus depreciation
and add additional 100 percent bonus depreciation in some cases.
[Bennett:11U] Drake Bennett: “Do the Unemployed Get a Second Act”; Bloomberg Businessweek, 14 Sep.2011. HHHH, WS Taxrates
[BennetW:13] Is College Worth
it?: A Former United States Secretary of Education and a Liberal Arts Graduate
Expose the Broken Promise of Higher Education; Thomas Nelson, 2013.
[BenningaS:97]‡ Simon Z. Benninga and Oded H. Sarig: Corporate Finance: A Valuation Approach; McGrawHill, 1997. Gordon Model in Chapter 1.
[BerleM:32]Adolf
A. Berle, and Gardiner C. Means: The Modern Corporation and Private Property;
Macmillan, 1932. Study about economic changes as
property becomes primarily owned by corporations.
[BerleMWJ:91] Adolf A. Berle, Gardiner C. Means, Murray L. Weidenbaum, and Mark Jensen: The Modern Corporation and Private Property; 1991. [BerleM:32]
BernardJS:06]
Andrew Bernard, J. Jensen and Peter
Schott: “Transfer Pricing by U.S.–Based Multinational Firms”; NBER working
paper 12493, Aug.2006. Y2000 data. Direct price methods from shipping data.
[Bernasek:10E] Anna
Bernasek: The Economics of Integrity;
Harper Studio, 2010. Have.
[Bernasek:10T] Anna
Bernasek: “Should Tax Bills Be Public Information?”; The New York Times, 13 Feb.2010.
Quotes
Kotlikoss, lenterSS [xls/Forest] .
[
[BettendorfEa09] Leon Bettendorf, Michael P. Devereux, Albert van der Horst, Simon
Loretz and Ruud A. de Mooij: Corporate tax
harmonization in the European Union; CPB Document 133,
Netherlands Bureau for Economic Policy Analysis, Nov.2009. Have, EU prefers
formulary apportionment to gain a common taxbase: sales, assets, &
employment . No harmonized rates.
BettendorfGvdH:06] Leon Bettendorf, Joeri Gorter, and
Albert van der Horst: "Who benefits from tax competition in the European Union?“; CPB Document 125,
CPB Netherlands Bureau for Economic Policy Analysis, 2006. <similar
paper cited in chap 10 as:09, lost?>
[BettendorfvdH:06]
Leon Bettendorf and Albert van der Horst, 2006. "Documentation of CORTAX“;
CPB Memorandum
161, CPB Netherlands Bureau for Economic Policy Analysis
[Bhagwati:06]
Jagdish Bhagwati: In Defense of
Globalization; Oxford Univ. Press, 2004. At Columbia Univ. Many citation and
examples. Not much consistency. No mention of taxhavens.
[BharadwajK:97]
Anandhi Bharadwaj and Benn R. Konsynski: Capturing the Intangibles, information
Week, 22 Sep 1997. Intangibles can be valued. Market value is best Tobin Q-ratio.
[BhattacharyaC:89]† S. Bhattacharya and G. M.
Constantinides (eds.), Theory of Valuation: Frontiers of Modem Financial
Theory, Rowman & Littlefield, Totowa, NJ.. 1989..
[BI:77] Business International: International
Licensing: Opportunities and Challenges in World-WideTechnology
Management, 1977, p. 121. Newsletters and reports published up to 1986 by Business International Corporation
(BI) “a publishing and advisory firm dedicated to assisting American companies
in operating abroad”. Not at SUL. Cited by [Caves:83] and [Contractor:81] .
[Biddle:13] Sam Biddle : Apple's Irish Tax Stash Is Actually Hidden in
New York City;
ValleyWag blog, 22 May 2013. [ACM]
[BittkerEa:3]
Boris L. Bittker et al.: Summary of Testimony of Panelists on tax Reform
Topics; House Joint Committee on
Internal Revenue Taxation, March 1973, 148 pp. Needless complexity. Depletion,
[Bickley:11] James
M. Bickley: Tax Reform: An Overview of Proposals in the 112th
Congress; Congressional Research Service, R41591, 20 April 2011.
[BierceEa:11] Bierce et al.: `Startup America’, A Vision for
American Entrepreneurs, What Role Global American Entrepreneurship?; Bierce
& Kenerson. Outsourcing-Law.com, 11 Feb.2011. No capital gains tax. Limited to C-corporations.
[Bingham:12] Amy Bingham: “Robin Hood Activists Look to Make Fairy
Tale a Realty”; ABC News, 19 June
2012.
[BirnbaumM:87]
Birnbaum and Murray, the tax reform act of 1986.
[Birnkrant:10]
H. Birnkrant: The Service's Approach to Transfer Pricing Takes a Drubbing from
the Tax Court In Veritas; Journal of
Taxation
, Vol.112 no.4, 2010, page 197.
[Bishop:08] Keith Paul Bishop: “Silver Standard”; Los Angeles Lawyer, Nov.2008, pp.32-42. California and
Nevada corporate taxes. Nevada has 2.66% of out-of-state corporations, while
Delaware has 91% of Calif. Corps, Local
Ca. 0.19% only
[BittkerEa:3]
Boris L. Bittker et al.: Summary of Testimony of Panelists on tax Reform
Topics; House Joint Committee on
Internal Revenue Taxation, March 1973, 148 pp. Needless complexity. Depletion,
[Bivens:11]‡ Josh Bivens: Failure by Design: The Story behind America's Broken Economy; Cornell University Press, Economic Policy Institute, 2011. Bought, past statistics, only vague recommendations.
[Bizac:93]
Rene Bizac: Transfers of Profits: The New Article 26 of the Belgian Income
Tax Code and Article 57 of the French General Tax Code - Siamese Twins? (Part
Two); INTERTAX 420, 430,
Sep.1993.
[Black:96] Fischer Black: Noise; Journal of Finance, July 1986 . Due to noise a
range of two can be expected in the market [p.530-533] .
[Blagdon:13] Jeff Blagdon:
Twitter the latest Company looking to play the tax avoidance Shell game; The Verge, 19 Oct.2013, www.theverge.com/2013/10/19/4854306/.... [ACM].
[BlairM:06] David B. Blair and Dwight N. Mersereau: “Chief Counsel revamps case-specific
advice procedures to match LMSB's new enforcement paradigms”; The Tax Executive, July-August, 2006.
[Blake:10] Rich Blake: Smaller Fish to
Fry – IRS targets self-Employed; ABC News,
9April 2010. $345B. In
2006, the IRS conducted around 1.2 million examinations of individuals who
earned less than $200,000; last year, there were around 1.3 million of those
types of examinations. Still, roughly 90 percent of the 1.4 million IRS audits
conducted in 2009 involved persons earning under $200,000. By comparison, the
IRS conducted just 28,349 examinations of individuals who earned more than $1
million. The bulk of the agency's audit resources are allocated to its Small
Business/Self Employment division. 150000B for self-employed schedule C filers.
[Blessing:09]‡ Peter H.
Blessing: testimony, Hearing on Banking Secrecy Practices and Wealthy American
Taxpayers; The Subcommittee on Select Revenue Measures of the House. Committee
on Ways and Means, 111th Cong. 2, 2009 http://waysandmeans.house.gov/media/pdf/111/pbless.pdf
(, Partner, Shearman & Sterling “It never will be possible
to eliminate criminal or fraudulent behavior in respect of financial accounts,
even such behavior on a very large scale.”).
[Block:09]
Cheryl D.Block: “Corporate Taxation:
Examples and Explanations 4th edition”; Aspen Publishers, 2004.
[Bloomberg:12] Bloomberg
View: “The Silliness of Soak-the-Rich Schemes”; Bloomberg Businessweek, 23 Mar 2012. Based on HM Treasury study the 50% tax
would only collect £2.4 instead of £7.8. Better get original study. 91
[xls/taxproposals]
[Bloomquist:03]‡ Kim M. Bloomquist:
Tax Evasion, Income Inequality and Opportunity Costs of Compliance; 96th Annual Conference of the National Tax
Association, 2003. Senior Economist,
Internal Revenue Service Office of Research: widening income inequality
contributes to the propensity to evade
[Blouin:12]‡ Jennifer Blouin: “Taxation of
Multinational Corporations”; Foundations and Trends® in Accounting: Vol.6
no.1, 2012, pp 1–64. http://dx.doi.org/10.1561/1400000017
Location
affected by taxation.
[BlouinKR:12]‡
Jennifer L. Blouin Linda P. Krull, and Leslie A. Robinson: Where in the world
are `permanently reinvested’ earnings?; SSRN 2154662, Sept. 2012; The
Accounting Review, Vol.87 no.5, Sept. 2012, pp.1463-1491. Regression on data from 1999 to 2004.. Uses permanent, although indefinitely is actually the expression used, refers to [BlouinKR:12A]‡
[BlouinKR:12A]
: Jennifer L. Blouin Linda P. Krull, and Leslie A. Robinson “Is U.S.
Multinational Dividend Repatrition Policy Influenced by Reporting Incentives?”
4663 jobs lost 1Q94
[BlumenthalS:96]
Marsha Blumenthal and Joel B.
Slemrod: “The Compliance Cost of taxing Foreign Income its Magnitude,
Determinants, and Policy Implications”; in [Slemrod:96] . a survey from
corporate data, Does not consider tax havens. [xls/taxes]
[BodieKM:08] Zvi Bodie, Alex Kane, and Alan J Marcus: Investments, 8th edition;
McGraw-Hill/Irwin, 2008. ( I have the 8th edition?, 9th edition
2010) <<check references bodie vs Brealey. Much on stock and bonds.>
[Boehm:81]†
Barry Boehm: Software Engineering Economics; Prentice-Hall, 1981.
[Boehm:88]†
Barry Boehm: "A Spiral Model for Software Development and
Enhancement"; IEEE Computer, Vol.21 no.5, May 1988, pp.61-72.
[Boehm:00]† Barry Boehm et al.: Software Cost Estimation with
Cocomo II; Prentice-Hall, 2000.
[Boehm:99]†
Barry Boehm: Managing Software Productivity and Reuse; IEEE Computer,
vol 32, No.9, Sept. 1999, pp.111-113.
[Bogoslaw:10]
David Bogoslaw: “Tough Times Spur
Shifts in Corporate R&D Spending”; Bloomberg
Business Week, 9 Aug.2010.
[Bohr:18] Niels Bohr: "It's hard to make predictions,
especially about the future”; quoting a Danish expression in 1918. <for bohr date check in Teaching and
Learning Elementary Social Studies (1970) by Arthur K. Ellis>
[BolchD:78]‡ Ben Bolch and William W. Damon: "The
Depletion Allowance and Vertical Integration in the Petroleum Industry"; Southern
Economic Journal, Vol.45, 1978, pp.:241-249.
[Bonasia:02]† J.
Bonasia: Firms Wringing Value from IT Units; Investors Business Daily,
21 Aug. 2002.
[BondS:01]†
Andy Bond and Jagan Sud: "Service Composition for Enterprise
Programming"; Proc. Working Conference on Complex and Dynamic Systems
Architecture, University of Queensland, Dec. 2001, Brisbane, Australia.
[BoortzL:06] Neil Boortz and John Linder: The Fair Tax book; 2006. States that 23%tax rate on all new goods and services
is revenue neutral. No corporate tax. IRS abolished, turn over tax collection
to be administered by states. Minus a prebate mailed monthly. Per {Bartlett:11]‡ a it is a flat like tax at
30% and rebates to individuals. Diatribe. Have. [xls/taxhavens] 91
[xls/taxproposals]
[
[BoultonLS:00]
Richard
Boulton, Barry Libert, and Steve Samek: Cracking
the Value Code; Arthur Andersen. Harper Business, 2000. Bought on Amazon
for $0.01! p.28: A company's value is
determined daily as millions of shareholders buy and sell its stock.
[BovenbergdM:94] A. Lans Bovenberg and Ruud A.. de Mooij: “Environmental Levies and Distortionary Taxation”; The American Economic Review, 1994, Vol.84 no.4 pp.1085-1089. Based on Baumal, . Considers affect on employment.
[Bowley:13C] Graham Bowley: “Shaky Agreements Over Fixing the Corporate
Tax System”; New York Times, 2 May 2013.
[Bowley:13D] Graham Bowley: “In Tax Overhaul Debate, large vs. Small
Comoanies”; New York Times, 23 May 2013.
[BradfordS:77] David F. Bradford and William E. Simon: Blueprints
for Basic Tax Reform; Office of Tax Analysis, US Dep. of the Treasury, 17 Jan.1977.
Income ,
consumption tax. In the model tax system corporate taxation is eliminated,
Making C-corporations like S-corporations. Very careful description and
discussion of many specific issues. True depreciation is advocated, but would
be even harder for intangible assets.
[BracewellG:09]
Proposed International Tax Reforms Open Critical Debate on Future of U.S.
Competitiveness; Bracewell and Giuliani,
26May 2009. Check-the-box
NBER Book
Series Tax Policy and the Economy; NBER, Vol.5, 1991.
[BradshawP:13]
Tim Bradshaw and James Politi: “Tim Cook: Apple’s Quitet leader”; Financial Times; 24 May 2013. Also many related
pointers to Cook’s Senate testimony. Video.
[Branch:74] Ben S. Branch: "Research and Development and Profits: A Distributed Lag
Analysis"; Journal of Political
Economy, September-Oct.1974, pp.999-1011. Uses patents as a metric of
R&D, lead to short lags fom invention to sales.
[Branch:02]
Ben Branch: “The Flat Tax: How to Fix It”; Presented to the 1997 Eastern
Finance Association meetings; Business Quest; http://www.westga.edu/~bquest/202/flattax.htm>. Useful justification of assumptions. 25%flat for income +
SSn 4100 exemption. Taxes currently are NOT really progressive ! (U mass,
finance), evasion and avoidance.
[BranchC:10]
Ben Branch and Cosette Chichirau: "Mispricing versus Risk Premiums in
R&D Intensive Firms"; International
Review of Financial Analysis. Vol.19, Issue 5, Dec.2010, Pages
358-367.
[BranchT:05]
Ben Branch and Gary Tameo: "Managing
a Pension Plan Shutdown in Chapter 7"; Journal
of Corporate Renewal, Vol.18 No.7, July 2005, July 2005, pp.8-13.
[BranscombEa:91]†
L. Branscomb (chair) et al: Intellectual
Property Issues in Software; Computer Science and Telecommunications Board,
National Research Council, National Academy Press, 1991,
<http://books.nap.edu/books/0309043441/html> .
[Break:95]
George F. Break: “Professional Opinions About Tax
Policy”; National Tax Journal, Vol.48
no.1 March 1995. 48, p.155-158.
[BrealeyMA:06]
Richard A. Brealey, Stewart V.
Meyers, and Franklin Allen: Principles of Corporate Finance, 8th edition; Mc
GrawHill 2006. P/e ratio.
[Brennan:10]
Thomas J. Brennan: “What
Happens After a Holiday?: Long-Term Effects of the Repatriation Provision of
the AJCA”; Northwestern Journal of Law and Social Policy,
Spring 2010. Research on repatriation.
[BrewerB:09] Mike Brewer
and James Browne: Can more income be raised by increasing income tax for the
very rich?; Institute for Fiscal studies, 2009,
<http://www.ifs.org.uk/bns/bn84.pdfl>.,
[BrewerBJ:12]‡ Mike Brewer,
James Browne and Paul Johnson: The 50p income tax rate: what is known and what
will be known?; Chapter 9 in The IFS Green Budget, Institute for Fiscal studies, Feb.2012. <http://www.ifs.org.uk/budgets/gb2012/12chap9.pdfl>
[BrickleySCW:02]
James A. Brickley, Clifford W. Smith, Jerold L. Zimmerman, Janice Willett:
Designing Organizations to Create Value: From Strategy to Structure;
McGraw-Hill Professional, 2002. ISBN 0071393927, 9780071393928, 320 pages.
Chapter 7 section 14 pages on transfer pricing, VIC Cap.4
[Brill:12]‡ Alex Brill: A
Pro-Growth, Progressive, and Practical Proposal to Cut Business Tax Rates; Tax
Policy Outlook, no.1, American Enterprise Institute, Jan 2012. Advocates gradually lowering Copr income tax to 25% -
gets rid of domestic preference, . Disallow 10% of C-copps interest
deductyibility. Make 50% depreciation permnant, gradually limit benefit for
home mortage deduction; remove state and local tax deduction. Repeal AMT.
[BriscoeOT:06] Bob Briscoe,
Andrew Odlyzko, And Benjamin Tilly: “Metcalfe's Law is Wrong”; IEEE Spectrum, 1 Jul.2006. It is more like n
log(n) than n2.
[Brittain:05] William
Brittain-Catlin: Offshore – The Dark Side
of the Global Economy; Farrar, Strauss and Giroux, 2005. Says: ‘In 2002 BP
had more than US$500m in offshore capital invested in various financial
instruments to speculate on the money markets, making it as much a bank as an
oil producer.’ Focus on Cayman. In 2001 Cayman had $800B in deposits. Have.
[Broder:97]
John M. Broder: Demonizing the I.R.S., Is an Overhaul needed, or Just less
Posturting; The New York Times, 20
Sep.1997.
[Bron
[Brooks:12] Sheena
Brooks: France Blacklists SKN as Offshore Tax haven”; The St.Kitts Nevis Observer, 1 May 2012. See also http://www.panamalaw.org/nevis_llc_and_nevis_bank_account.html,
[<http://www.irs.gov/pub/irs-apa/study_guide_exhibit_g.pdfl>
[Brown:00]‡
Alvin Brown: Testimony from Alvin Brown published by the House Ways & Means
Committee of the U.S. Congress; <http://www.irstaxattorney.com/offer-in-compromise/testimony_Alvin_brown_2.html>. On Taxliens. Was with the IRS for 27 years.
NBER Book Series Tax Policy and
the Economy; NBER, Vols.23-26, 2009-2012.
[Browne:12]‡ James Browne: The 50p
income tax rate; presentation slides , Institute for Fiscal studies, March
2012, <http://www.ifs.org.uk/budgets/budget2012/budget2012jamesbrowne.pdfl>. Also uses Laffer curve.
[BrownEa:12] Jim
Brown et al.: “Report on the Mangement and Control Provision of the `International
Tax Competiveness Act of 2011’”; New
York State Bar Association, Tax Section, Report no.1232, 31 January 2011. Treats certain CFCs as domestic
corporations. Analysis of Lloyd Dogget, HR 5328.
[Brownlow:03]‡
Graham A. Brownlow: Fiscal Decentralization in Ireland; Instutut de Recherces
Economiques et Fiscales (IREF), 2003.
[Browning:07] Lynnley
Browning: “Gimme Tax Shelter”; The New
York Times, 4 Feb.2007, business section.
Globalization. Netherlands, musicians.
[Browning:07G] Lynnley Browning: “A designer handbag
Amid the Briefcases on the Tax Beat”; The
New York Times, blog, 31 Aug.2007. Article on Lee
Sheppard of Tax Analysts..
[
[Browning:11] Lynnley Browning: “Microsoft’s Use Of Low-Tax Havens Drives Tax Bill to 7 Percent Of Profit”; Reuters / Huffington Post Business, 28 July 2011. Sales 14.4B, 30% increase in after in after-tax profit, 35% gain in earnings per share, 445M in taxes in the US 7% of 6.32 B in pre tax profit. With Dena Aubin, David Cay Johnston, Scott Malone and Bill Rigby, editing by Martin Howell). Puerto Rico: unusual credits. [xls/forest] ..[ACM].
[BruinsESS:23]
M. Bruins, M. Einaudi, M. Seligman and Sir Josiah Stamp: Theoretical Study of
Double Taxation; for League of Nations,
report (document F.19) published in March 1923.
[Brynjolfsson:98]†
Erik Brynjolfsson and Lorin Hitt: "Beyond
the Productivity Paradox";
Communications of the ACM, Vol.41, No.8, August 1998, pp.49-55.
[Bucci:03]
Alberto Bucci: "R&D, Imperfect Competition and Growth with Human
Capital Accumulation“; Scottish Journal of Political Economy, Scottish Economic Society, Vol.vol.50 no.4,
2003, pp.417-439, 2009. Human resources will move to where it is most
profitably employed, no tax effects, theroretical.
[Buchheit:12]
Paul Buchheit: Who Takes the Gold for Tax Avoidance in 2011?; Nation of
Change, 9 Apr 2012 <http://www.nationofchange.org/who-takes-gold-tax-avoidance-2011-1333979061>.
[Buchheit:13]
Paul Buchheit: Add it Up: The Average American Family Oays $6000 a Year in
Subsidies to Big Business; Nation of Change, 23 Sep.2013. <http://www.nationofchange.org/add-it-average-american-family-pays-6000-year-subsidies-big-business-1379950004>
Very rough numbers. The
estimate for sheltering in tax havens is $1,231 and for R&E credits and
othe Corporate tax expenditures is $870.
[Buckley:04]
William M. Buckley:” IBM documents give rare look at offshoring”;Wall Street Journal, 19 Jan.2004., p.
1A.
[Buckley:11]
John L. Buckley, ‘‘Tax Expenditure Reform: Some Common Misperceptions’’; Tax Notes, 18Jul.2011, p.
255, Doc
2011-13056,
or 2011
TNT 138-6.
[BucovetskyH:05]
Sam Bucovetsky and Andreas Haufler: “Tax Competition with Endogenous Mobility
of Firms: Should Tax Loopholes for Multinationals be Closed?”; Mimeo, York
University, May 2005.
[BucovetskyH:08]
Sam Bucovetsky and Andreas Haufler: “Preferential Tax Regimes with asymmetric
Countries”; Munich Discussion paper 2006-30, Dep. of Economics, University of
Munich, Oct.2006.
[BucovetskyW:91]
Sam Bucovetsky and John D. Wilson: Tax Competition with Two Tax
Instruments”; Regional
Science and Urban Economics, Vol.21, 1991, pp 333-350.
[BuettnerW:09] Thiess
Buettner & Georg Wamser: "Internal Debt and Multinationals' Profit Shifting - Empirical Evidence
from Firm-Level Panel Data“;Oxford
University Centre for Business Taxation, Working
Paper 0918, 2009.
[Buffett:11] Warren Buffett:
“Stop Coddling the Super-Rich”; The New
York Times, 14 Aug.2011.
[BughinM:13]
Jacques Bughin and James Manyika: Measuring the full impact of digital capital;
McKinsy report, July 2013. As ij 31 July
2013, BEA data includes R&D investment.
[Burback:98]†
Ron Burback: The Water Sluice Method for Software Development; Stanford
University CSD thesis, 1998.
[Burman:89]‡ David
Burnham: A Law unto Itself:
Power, Politics, and the IRS; Random House, 1989. Documents improper behavior, motivated
rrestructuring.
[Burman:99]‡ Leonard E. Burman: The Labyrinth of
Capital Gains Tax Policy; Brookings Institution, 1999.
[Burman:03] Leonard E. Burman: Is the Tax Expenditure Concept Still Relevant?; National Tax Journal, Sep.2003. The author is with The Urban, The Tax Policy Center. Georgetown University.
[Burman:11] Leonard E. Burman: Tax Reform Options: Marginal Rates on High-Income Taxpayers, Capital Gains,
and Dividends; Statement
before the Senate Committee on Fianace, 14 Sep.2011. Tax capital gains as income, use revenue to cut
corporate tax. Nice
graphs.
[Burman:99] Leonard E. Burman:
The Labyrinth of Capital Gains Policy: a Guide for the Perplexed; The Bookins Institution, 1999.
[BurmanGT:08] Leonard E. Burman, Christopher Geissler, and Eric J. Toder: “How Big
Are Total Individual Income Tax Expenditures, and Who Benefits from Them?”; American Economic Review, papers and
proceedings, Vol.98 no.2, May 2008, pp.79-83.
[BurnhamO:05] Paul Burnham and Larry Ozanne: Taxing Capital Income,
Effective Rates and Approches to Reform; Congressional Budget Office, Congress
of the United States, Oct.2005. Ignores IP, shows
strong effect of borrowing versus equity financing. Proposes a.o
non-deductabilty of interest and effect on effective tax rates, but not the
amount lost.
[Burns:12]‡ Alexander Burns:
Romney Endorses Ryan Plan; Politico,
20 March 2012.
[Bush:05] George W. Bush: President's
Advisory Panel on Federal Tax Reform: "Simple, Fair, and Pro-Growth:
Proposals to Fix America's Tax System"; 1 Nov. 2005, Doc
2005-22112, 2005 TNT 211-14. Comprehensive Business Income Tax (CBIT) proposal . To be applied to
all businesses equally. Corporate intrest would not be deductinble, but taxed
at 31.5% Eliminates taxation of
dividendsd. Individual interest would not be taxed. [see Sullivan:11] ,[
Gideon:05]
[BusinessWeek:05]
BW: Taxes: A race to the bottom; 4 April 2005
[Butler:09] Eamonn Butler: "Save the tax havens – we need them"; The Times of London: 4 Dec 2009.
[Byrne:12] Janet Byrne (ed.), The Occupy Handbook; Back bay
Books, 2012. On Kindle
[ByrnesL:03] Nanette Byrnes and Louis Lavelle: The Corporate Tax
Game; Business Week, 31 March
2003. Marriott. Limited IRS capability.
[Cairncross:97] Frances Cairncross: The Death of Distance; Orion, 1997. Have.
[Camp:11] David
Camp: Tax Reform Act of 2011; Ways and Means Discussion Draft, House of
Representatives, 26 Oct.2011. Favors territorial taxation
[Campbell:92]
Charles G. G. Campbell: Availability and Effects of Host Country Transfer
Pricing Administrative Rulings (France); Tax
Mgm't. Int'l Forum; Vol.13 no.4, 1992.
[CampbellW:12] Matthew Campbell and Zijing Wu: “Why Europe’s Tech
Firms Love New York”; Bloomberg
Businessweek, 9 April 2012, pp.56-57.
Price/book
value of MSCI US Information Technology Index is 3.7. Information on market to book ratio and IPO’s.
3.7 for MSCI index IT companies.
[Cantley:03] Beckett G. Cantley: “Corporate
Inversions: Will the REPO Act Keep Corporations from Moving to Bermuda?”; Houston Business and Tax Law Journal, Vol.3,
2003. Available at SSRN: <http://ssrn.com/abstract=434760 ??AAAA
have More footnotes than paper. US
corporate shareholders loose dividebd
deduction. Adventerous tax planning, REPO became part of the AJCA
[Caplan:08]
Bryan Douglas Caplan The Myth of the Rational Voter: Why Democracies Choose
Bad Policies (New Edition) ;
Princeton Univ. Press, 2008.
[CaplowHW:05?] Theodore Caplow, Louis Hicks,
and Ben J. Wattenberg: The First Measured century: An Illustrated Guide to
Trends in Amaerica, 1900-2000; PBS. . Includes Middletown
study < http://www.pbs.org/fmc/book.htm.>
[Carl:06] Walter J. Carl: “What's all the buzz about? Everyday
communication and the relational basis of world-of-mouth and buzz marketing
practices”; Management Communication Quarterly,
Vol.19 no.4, May 2006, pp.601-634.
[CarlsonFG:06]
Murray Carlson, Adlai Fisher, and Ron Giammarino: Corporate Investment and Asset
Price Dynamics: Implications for SEO Event Studies and Long-Run Performance;
The Journal of Finance, Vol.61, Issue
3, June 2006, pp.1009–1034.
[CarmelA:02] Carmel, E. & Argawal, R. “The
Maturation of Offshore Sourcing of InformationTechnology Work”; MISQ Executive, Vol.1 no.2,
2002, pp.65 – 77. Globalization.
??NNNN
[CarmichaelEa:09]‡ Philip
Carmichael, Brian A. Cromwell, Holly E. Glenn, Robert S. Kirschenbaum, Gregg D.
Lemein, Marc M. Levey, Holly K McClellan, Margreet G. Nijhoff, John M.
Peterson, and Salim R. Rahim: IRS Issues Long-Awaited Temporay Regulations on
Cost Sharing Arrangements; Baker & McKenzie, 12 Jan 2009.
Based
on investor model issued 2005. uses platform contributions. (PCT) Ersn profit
on R&D contribution. Temp. Treas. Reg. § 1.482-7T(c)(5) (Example 2). narrower
range of deviations Temp. Treas. Reg. §
1.482-7T(c)(5). (Example 2). Now a finite period. Temp. Treas. Reg. §
1.482-7T(c)(5)(Example 2).. Temp. Treas. Reg. § 1.482-7T(c)(5) (Example 2)..
Difference in risk. Moreover, the 2005 proposed regulations provided that
external contributions may include an expert R&D team and suggested that an
assembled R&D workforce may constitute a valuable intangible. The Preamble
to the 2005 proposed regulations stated that “[T] he Treasury Department and
the IRS believe that a contribution of such an experienced team in place would
result in the contribution of intangible property within the meaning of
§1.482-4(b) and section 936(h)(3)(B) (emphasis added).” The temporary
regulations do not limit platform contributions that must be compensated in
PCTs to the transfer of intangibles defined in section 936(h)(3)(B). If the PCT
Payee contributes the services of its research team for purposes of developing
cost shared intangibles pursuant to the CSA, the PCT Payor would owe
compensation for the services of such team under Temp. Treas. Reg. §1.482-9T.
The temporary regulations provide that treatment of the contribution of
services of a research team as controlled services is without any inference
concerning the potential status of workforce in place as an intangible within
the meaning of section 936(h)(3)(B). Thus, the temporary regulations purport to
decouple the compensation due for an assembled work force and the finding of an
intangible transfer, perhaps recognizing that the definition of intangibles
under section 936(h)(3)(B) is not as broad as the IRS might have wished.
[Carney:13]
Tim
Carney: How corporate tax credits got into the `cliff’ deal; Tax Notes. 2 Jan .2013. Refers to the The
Family and Business Tax Cut Certainty Act of 2012
Carr:12]‡
Beth Carr:: Statement to Congress; International Tax Services, Ernst & Young LLP, Permanent
Subcommittee on Investigations, U.S. Congress, 20 Sep.2012. Works for HP.
[Carson:08] Ron Carson: “Intellectual Property Audit and
Management”; Chapter 33B in [ParrS:05]‡,
2008 Cumulative Supplement, Wiley 2008.
[CarterK:11]‡ Zach Carter and Sara Kenigsberg: Panama
Trade Deal Would Undercut Efforts To Get Rich Americans To Pay Taxes;
Huffington Post, 9 Aug.2011, also a
video,
Banking secrecy, $200 to set up a corporation. [xls/taxhavens]
[Cassanos:03]
Robert Cassanos: “Single Taxation of Publicly Traded Entities”; Tax Notes. Vol.99 June 16, 2003, pp.1663-1681.
[Cassidy:11]
John Cassidy: “The Demand Doctor”; Annals
of Economics, New Yorker Magazine, 10 Oct 2011 – What would John Maynard Keynes tell
us to do now – and should we listen? “the main impediment
[Cassidy:13]
Mike Cassidy: Google sues IRS Over AOL In Today’s A;lphabet Soup Winner;
Mercury News, 28 Jun 2013.
[Castle:11] Stephen Castle: Europeans Introduce Corporate Tax Plan; The New York Times, 10 March 2011. Tension beween
Ireland and the EU n 12.5% taxralte Ch.8.
[CavalliSforzaF:81] Luigi Luca
Cavalli-Sforza and Marcus W. Feldman: Cultural
Transmission and Evolution: A Quantitative Approach; Princeton University
Press, 1981.
[CavenaughEa:04] John
Cavenaugh, Jerry Mander, et al.: Alternatives to Economic Globalization, A
better World Is Possible; Report of the International Forum On Globalization,
2nd Ed., Berrett-Koehler, 2004. Have, diatribe. $300B more outsourcing
is possible for service jobs per McKinsey.
[Caves:82] Richard
E. Caves: Multinational Enterprises and
Economic Analysis, 1st ed.; 1982 , have 3rd
edition.
[Caves:07] Richard E. Caves: Multinational
Enterprise and Economic Analysis, 3rd Ed ; Cambridge University Press, 2007. Have. Many multinationals exist because of a failure in the market
for intangibles. Intra-form transactions are more profitable
[CavesCK:83] Richard E. Caves, Harold Crookell, and J. Peter
Killing: "The Imperfect Market for Technology Licenses"; Oxford
Bulletin of Economics and Statistics, 1983, pp.249-268. many multinationals exist because of a failure in the market for intangibles.
Intra-firm transactions are more profitable
[CBO:05] CBO: Corporate
Income Tax rates: International Comparison; Congressional Budget Office,
Congress of the United States, Nov.2005. Shifting sources. Ignores investments in
intangibles. Companies will invest in countries
with lower taxrates (Chap.6, <10>) <not that simple>
See
[Shulman:10R]
[CBO:08] CBO:
Revenues, Outlays, Deficits, Surpluses
and Debt Held by the Public, 1968 to 2007; Congressional Budget Office,
Congress of the United States, Sep.2008. <http://www.cbo.gov/budget/data/historical.pdfl>. Includes GDP [xls/taxes]
[CBO:11] CBO: The Budget and Economic Outlook: Fiscal Years
2011-2021; Congressional Budget Office, Congress of the United States, Jan.2011.
<http://www.cbo.gov/ftpdocs/120xx/doc12039/01-26_fy2011outlook.pdfl>
[CBO:12] CBO: Comparing the Compensation of Federal and
Private-Sector Employees, Congress of the United States, Jan.2012. http://www.cbo.gov/ftpdocs/126xx/doc12696/01-30-FedPay.pdfl
[CCH:09] CCH Editorial Staff: Internal Revenue Code; 2 volumes, CCH Wolters Kluwer, Winter 2009. The material is also available on-line at the IRS web
site and at [LLI:92]‡
[CCH:10] CCH Editorial Staff: Income Tax Regulations, including proposed regulations; 7 volumes,
CCH Wolters Kluwer, Winter 2010. The material is
also available on-line at the IRS web site and at [LLI:92]‡
[CGSCF:10]‡ Entrepreneurship and Expeditionary Econmics, Kauffmam,
Command and General Staff College Foundation, cites ketsdever
[Censky:11] Annalyn Censky: “Boost spending on equipment, create more Jobs”; CNNMoney, 12 Sep.2011.
[CerfK:00] Vint Cerf and Bob Kahn: "Al Gore and the Internet"; 29 Sep.2000, <http://amsterdam.nettime.org/Lists-Archives/nettime-l-0009/msg00311.html> . "As far back as the 1970s Congressman Gore promoted the idea of high-speed telecommunications as an engine for both economic growth and the improvement of our educational system. He was the first elected official to grasp the potential of computer communications to have a broader impact than just improving the conduct of science and scholarship [...] the Internet, as we know it today, was not deployed until 1983. When the Internet was still in the early stages of its deployment, Congressman Gore provided intellectual leadership by helping create the vision of the potential benefits of high speed computing and communication. As an example, he sponsored hearings on how advanced technologies might be put to use in areas like coordinating the response of government agencies to natural disasters and other crises
[CeriB:12]
Stefano Ceri and Marco Brambilla: Search
Computing; Springer
MNCS vol 7538, 2012.
[CFRB:12]‡
Committee for a Responsible Fderal Budget: Raising Revenues from Higher Earners
through Base Broadening; 15 Nov. 2012. Uses TPC data New rates anove 250K inconme. Dividends at 20%
from 15% raises $1B/y, $7B/ 10y, at 39.6% versus 20% raises $10B/y,$104B/10y. Capgains 15% to 20% raises $7B,
$57B/10y. Versus cap deduction to $25K
progressive to $500K = $57B, 91 [xls/taxproposals]
[ChadwickEa:10]‡
Alex Chadwick, Marcello Distaso, Guilaume Le Camus, Philippe Lion, and Rodrigo
Ogea (eds): European Tax
Transactions Guide; Baker & McKenzie, Tax Europe, 2010.
John Chambers: U.S. Jobs, innovation, Growth and Investment; Cisco Blog, 5 November 2010. 1 Trillion $ offshore. Lobbies for repatriation. Wih Safra Catz of Oracle. It costs the U.SD. taxpayer nothing. Earlier:: “most people forget that in a high-tech acquisition, you really are acquiring only people”[i]. [ACM].
[ChapotonG:88] O. Donaldson Chapoton and Lawrence B. Gibbs: A Study of
Intercompany Pricing; Claitor’s publishing; Discussion Draft, U.S. Treasury Department, 18 Oct.1988.
Also referred to as the 1988 White Paper. page 121. Cost sharing was
originally viewed as a way to allocate intangible income among related parties
without requiring the complex determination of intercompany royalty rates. See
also preamble to the 1995 cost sharing regulations. page10: thousands of
different transactions. IRS p.14 Acces to pricing information p15: acess to
foreigb accounts §982 for summons, p.21
Transfer of know how as services. p.54 Section 367. P:74 Safe Harbor p.109
Risk, History of Cost Sharing On PC Kindle as study of Intercomp00unit.azw.
Ordered. Foreign source R&D, Questions validity or arm’s length (Chap.10).
[ChatfieldG:73]†
C. Chatfield and G.J. Goodhardt: “A Consumer Purchasing Model with Erlang Interpurchase
times”; Journal of the American
Statistical Association, Dec 1973, Vol.68, pp.828-835.
[ChenWS08]
Roger C.Y. Chen, Chao-Shi Wang, and
Ru-Ping Shi:: “R&D intensity and the performance of IPOs “;International Journal of Innovation and Learning, Vol.5, no.3, 2008, pp.241-254.
..[ACM].
..[ACM].
[ChoiSW:97] Song-Yong Choi, Dale O. Stahl, and Andrew Whinston: The Economics of Electronic Commerce;
Macmillan, 1997.
[ChoiH:04] Eun Kwan Choi and James Hartigan (eds.): Handbook of International Trade, Vol.1;
Basil Blackwell, 2004. don’t have?
[ChoiH:05]‡
Eun Kwan Choi and James Hartigan (eds.): Handbook
of International Trade, Vol.2; Basil Blackwell, 2005. have. Disconnect of law and economics.
[Clark:07]
Gregory Clark: A Farewell to Alms: A Brief Economic History of the World; Princeton University Press, 2007, ISBN:
978-0-691-12135-2.
[ClarkSP:99]
Richard A. Clark, Hy Sanders, and Lawrence D. Powell: Global Transfer Pricing; TALS, Deloitte & Touche, Oct.-Nov.1999,
pp.13-20. See D&T.
[ClarkSP:99]
Richard A. Clark, Hy Sanders, and Lawrence D. Powell: Global Transfer Pricing;
Deloitte & Touche, October-November 2009, pp.13-20.
[Clevenger
CS:03] Novella Clevenger, Martha Crumpacker, and Ray Siehndel: Corporate
Inversion: A Symbol of a Changing Paradigm of Corporate Behavior? Balancing
Global Competitiveness, Fiduciary Duty, and Ethical Behavior; Washburn
University Working paper series no.2 - Nov.2003.
[ClintonG]
William Clnton and Albert Gore: Reinventing Envisonmental Regulations; EPA,
1995.
ChristensenCN:01]
K.
Christensen, R. Cline, and T. Neubig: “Total corporate taxation: `Hidden’”; National
Tax Journal,
Sep.2001, Vol.54 no.3, pp.495-506. above-the-line,
non-income taxes
[ChristensenR:03] Clayton M. Christensen and Michael E. Raynor: The Innovator's Solution: Creating and
Sustaining Successful Growth; Harvard Business school, 2003.
[Christians:09]
Allison Christians: “Sovereignty, Taxation, and Social
Contract”; Minnesota Journal of
International Law, Vol.18, August 2009, p.99. < http://ssrn.com/abstract=1259975>.
Global vs national issues.
US tax initiatives, OECD. Good citations. Sovereign countries have the right
not to tax.
[Chou:03]†
Tim Chou: "The Hidden Cost of Software"; ASP news,
www.aspnews.com/strategies, May 29, 2003.
it
is clearly the business of the Government to watch for loopholes, and to
propose remedial measures from time to time”;, “t is our duty to close these
loopholes as far as possible before they are so widely resorted to as to injure
the revenue”;
[Ciesielski:12]
Jack
T. Ciesielski: Statement to Congress; R.G. Associates, Inc., Permanent Subcommittee on Investigations,
U.S. Congress, 20 Sep.2012. Deferral does not
affect tax law. Management has a valid reason bias to foreign investment.
Equity-based investment. Incentive problems. Deferral stated in 1959, but more
easy to use now, IASB did not act on the issue in 2004. Invetors don’t know
what is going on. 1.5T accumulated in
S&P 500 firms. 72% owned by 18 companies.
[CIA:11]‡ [xls/taxhavens]
[CIP:05] Dept.
of the Treasury: Coordinated Issue Paper; Large and Medium Size Businesses,
IRS, LMSB-04—0907-9227, to be effective Sep.2007, first presented as Proposed
Treasury Regulation §1.482-7(g)(4), 29 Aug.2005; Updated 30 jan 2012. . <refer to app B?>.
[Clark:10] Sue Clark: Letter of response to Martin Hearson,
ActionAid UK; SABMiller plc, 11 Nov.2010, <http://www.actionaid.org.uk/doc_lib/sabmiller_right_of_reply_and_response1.pdfl>, retrieved 9 Dec.2010. Gv
[Clarke:76]‡
Darral Clarke: Cumulative Advertising Effects, Sources and Implications, Report
no.77-111, 1977, Marketing Science
Institute, 1976. IP life, measuments varied from 1.3 to 1368 months, cigarettes 17-677
month, also to 90 total.
[Clarke:99] William Clarke: How
the City of London Works; Sweet and Maxwell, 1999.
[ClarkEa:02]
Richard A. Clark, Hy Sanders, and Lawrence D. Powell: "The Arm's length
Standard"; Deloitte & Touche, Washington National Transfer Pricing
Team, Washington DC, 2Q2002; Review of IRS procedure 2002-52. <http://www.deloittetransferpricing.dk/UserControls/Publications/TALS/TALS%20-%202002%20-%202.pdfl>
[Clausing:03] Kimberly Clausing: “Tax Motivated Transfer Pricing and
U.S. Intrafirm Trade Prices”; Journal of
Public Economics, 2003, pp.2207 – 2223,
[Clausing:04] Kimberly Clausing: The American Jobs Creation Act of
2004, Creating Jobs for Accountants and Lawyers; Urban-Brookings Tax Policy
Center, Dec.2004. 7.4% is corporate
tax. Summarizesovisions. Gain $49B, cost
77B domestic production + 7B breaks `revenue raisers 82B+43B for repatriation
[Clausing:05] Kimberly
Clausing: The role of U.S. Tax policy in Offshoring; Working paper,
Dept.of Economics, Reed College, June
2005. Globalization.
??IIII
[Clausing:06] Kimberly Clausing: “International Tax Avoidance and
U.S. International Trade”; National Tax
Journal, June 2006. <http://www01.entrepreneur.com/tradejournals/article/149986064_1.html> Multinational undertake 70% of US int. trade, and 41 %
is intrafirm.
[Clausing:09] Kimberly A. Clausing: “Multinational Firm Tax Avoidance
and Tax Policy”; National Tax Journal,
Vol.62 no.4, Dec 2009, pp.703-725. Here is the abstract: This paper considers
the tax policy consequences of both real and financial types of international
tax avoidance, focusing on U.S. multinational firms over the period 1982–2004.
First, income shifting is examined by estimating the relationship between U.S.
affiliate profit rates and foreign country tax rates. Second, the effects of
taxes on multinational firms’ real operations across countries are considered.
Estimates of both financial and real responsiveness to tax rate differences
among countries are used to calculate how profits would differ from their
current levels absent tax incentives, and thus how U.S. government revenues are
affected. Finally, several policy alternatives are discussed, including
formulary apportionment.
[
Clinton:11] Hillary Clinton: Remarks preceding President Hu’s
State visit to the U.S.; U.S. Department of State, 14 Jan.2011.
[CMSR:11] Centre for
International Cooperation and Development: Corporate income tax; Slovenia, document
ACT-2, 2011, www.cmsr.si/en/.
[Coase:60] Ronald H. Coase: “The Problem of Social Cost”; Journal of Law and Economics, Vol.3, Oct.1960, The University of
Chicago Press, pp.1-44.
[Coase:88] Ronald H. Coase: “The Nature of the Firm: Influence”; Journal
of Law, Economics, & Organization, Vol.4, No.1 (Spring, 1988), Oxford University Press, pp.33-47.
[Coase:12] Ronald H. Coase: “Saving
Economics from the Economists”; Harvard Business Review Magazine, Dec.2012.
[Cobourn:07] Bill Cobourn:
Exploiting intellectual property in a complex World; Technology Executive
Connection, Vol.4, based on a survey by The
Economist, March 2007. File tecv4ip.pdfl>.
[CoburnH:12]‡ Tom Coburn with John Hart: Breach of Trust, How Washingon turns Outsiders
into Insiders;
[Coburn:12]‡ Tom Coburn: Statement; U.S. Congress, 20 Sep.2012. Congress
is to blame, it’s all legal. Code is too complex. Thinks s the difference is between 27 and 18% off shore, but
its 4%.
[Coglianese:11] Cary Coglianese:
Federal Agency Use of Electronic Media in the Rulemaking process; Final Report
to the Adminstrative Conference of the United States, Dec 2011; also “Enhancing Public Access to Online Rulemaking
Information”; Michigan Journal of Environmental and Administrative Law, 2012.
[:11] :
“Federal Regulations: Let's Review the Rules”; Los Angeles Times,
29 April 2011; RegBlog, Univ.of
Pennsylvania Law School, 29 April 2011.
[Coglianese:12] Cary Coglianese: Regulatory Breakdown: The Crisis of Confidence in U.S. Regulation;
University of Pennsylvania Press, 2012. Have. Pigouvian
taxation. 2Taxes vs. subsidies p.156.
[Coglianese:12E] Cary Coglianese: “Enhancing Public
Access to Online Rulemaking Information,” Michigan Journal of Environmental
and Administrative Law, 2012.
[:07] Robert
A. Kagan: Regulation and Regulatory Processes; Ashgate, 2007.
[CoglianeseN:01] , Cary
Coglianeseand Kalypso Nicolaidis: “Securing Subsidiarity: The Institutional
Design of Federalism in the United States and Europe”; in Kalypso Nicolaidis and Robert Howse
(eds): The Federal Vision:Legitimacy
and Levels of Governance in the United States and the EuropeanUnion, Oxford
University Press, . 2001.
[CohanA:12] William D. Cohan
and Jonathan Alter: “A fair and
Balanced Plan for Eliminating the Corporate Income tax”; Bloomberg Businessweek, 25 June 2012.
[Cohen:11]
Norma Cohen: Multinationals face more tax audits; Financial Times, 3 May 2011.
[Cohn:12]‡
Michael Cohn: IRS Commissioner Shulman Addresses Tax Delays; Accounting Today,
22 Mar. 2012. Too may temporary provisons in the tax
code.Bush tax cuts undecided. 2012 Budget cit by $300M
[CohnC:11] Peter Cohn and
Mathew Caminiti: The Multinational Advantage; Bloomberg Businessweek, 20 and 24 Jan 2011. Uses data from [MarkleS:09]‡ North
Carolina study.
[Collier:10, Paul Collie: The Plundered Planet; Oxford University Press, 2010.
[Collier:10W] Paul Collier: The political Econmy of
Natural Resources; Social Research, Vol.77 no.4 Winter 2010: , professor of
economics, Oxford University, and Michael Spence, 2001 Nobel Laureate in
economics . “‘Currently there
is both an agency problem – ministerial corruption – and an information
asymmetry: companies know better than governments what rights are worth. The
consequences are often grotesque… In 2006 the Democratic Repub?>
[Collins:11D] Chuck
Collins: Stop Corporate Tax Dodging: Talking Points and Background Information;
Institute for Policy Studies, 23 Mar.2011.
Picture of Ugland house
[Collins:11I] Lauren
Collins: “House Perfect, is the IKEA concept comfy or creepy?”; The New Yorker magazine, 3 Oct.2011. Includes IKEA’s
tax avoidance.
[CollinsS:99] Julie H. Collins and Douglas
B. Shackelford: Corporate Domicile and
Average Effective Tax Rates; in [Slemrod:99]
. Canada, Japan, UK, US. Does not consider Tax havens
[
[
[Conard:12] Edward Conard: “Unintended Consequences: Why Everything You’ve Been Told About the Economy Is Wrong”; Portfolio, 2012. Bain Capital participant
[Conason:11]
Joe Conason: Exclusive: John Kerry Says "Chinese Are Laughing All The Way To The
Bank" Over Prospect Of U.S. Credit Downgrade; National Memo, Thu, 07/28/2011 - 5:15pm
[ConnerS:09] Patrick D. Conner, E. Andrew Southerling: New SEC Chairman Mary L. Schapiro Pledges
Swift and Vigorous Enforcement; Morgan Lewis Litigation Practice, 12 feb 2009
[ConnicM:83] Connick v.
Myers:
461
U.S.
138; United States Supreme Court 461 U.S. 138; 1983, <http://straylight.law.cornell.edu/supct/html/historics/USSC_CR_0461_0138_ZO.html> "Whether an employee's speech
addresses a matter of public concern must be determined by the content,
form, and context of a given statement, as revealed by the whole record”.
[Constantinides:89]† G. M. Constantinide : , “Theory
of Valuation: Overview and Recent Developments”; in [BhattacharyaC:89] . on Beta.
[Contractor:81] Farok J. Contractor: International Technology Licensing, Costs and Negotiation; Lexington Books, 1981. p. 125. –have chapter around that page.
[Contractor:85]‡
Farok J. Contractor: Licensing in International
Stratgy, A Guide for Planning and Negotiation; Praeger,
1981.
[Contractor:01] Farok J. Contractor (ed):Valuation
of Intangible Assets in Global Operations;
Quorum, 2001. Collection of papers, have, Bargaining in IP negotiations [p.16]
, arm’s-length lag [p.120] . Bin Srinidhi: MNEs will devlop intangibles [p,173]
. Profits under the 3 IRS methods [p177] . IP life [p220] . Ravi Sarathi: Ownership
of software [p.225] . CISCO acquisitions [p.243] . Elisabeth King: Valuing the
workforce [p.264]
[Contractor:00] Farok Contractor: “Valuing Intangible Assets and Corporate Knowledge: Some General Principles”; Knowledge and Process Management, Vol.7 no.4, Oct.2000.
[Contractor:02G]
Farok Contractor: “The Growth of
Alliances in a New Knowledge-Based Economy”; International Business Review,
Vol.11, No 4, Aug.2002.
[Contractor:02K]
, Farok Contractor: “How Knowledge
Attributes Influence Alliance Governance Choices; A Theory Development Note”; Journal of International Management,
Vol.8 no.1, Spring 2002.
[CookC:10] Nancy
Cook and Eric Cook: System and method for analyzing tax avoidance; US patent
7,716,104 B2, granted 11 May 2010. Focus on interstate transfers . Refers to IRC
482. Parameter-based. Chapter 5 formulas,
ratios.
[CordesEG:05] Joseph J. Cordes, Robert D. Ebel , and Jane G.
Gravelle: Encyclopedia of Taxation and
Tax Policy; Urban Institute Press, Oct.2005.
[Cornez:00]‡
Arnold Cornez: The Offshore Money Book:
How to Move Assets Offshore for Privacy,
Protection, and Tax Advantage, 2nd Ed; Contemporary Books, 2000. Mentions IP,
p.57,58.
[Cornford:04] Andrew Cornford: Enron and
Internationally Agreed Principles for Corporate Governance and the Financial
Sector; G-24 Discussion paper 30, UNCTAD, June 2004.
[CorradoS:04]†
Carrol Corrado and Dan Sichel: "Measuring Capital and Technology: An
Expanded Framework"; Federal Reserve, Aug.2004,
<http://www.federalreserve.gov/pibs.feds/2004/200465/200465pap.pdfl>.
[Corrigan:09]
Conn Corrigan: Irish Economy at risk in Obama tax plan; Irish Central, 4 May
2009, updated 23 July 2009.
[Cosper:12] Susan M.
Cosper: Statement to Congress; Technical
Director Financial Accounting Standards Board, Permanent Subcommittee on Investigations, U.S. Congress, 20 Sep.2012. Explains FASB, determines GAAP standards. Does not
control actual tax law. Deferral guideline in indefinite deferral, ABP23.
[CovaDZ:11] Bernard Cova, Daniele Dalli, and Detlev Zwick:
“Critical perspectives on consumers’ role as ‘producers’: broadening the debate
on value co-creation in marketing processes”; Marketing Theory, vol.11 no.3,
Sep. 2011, pp.231-241. from Sonny
Chan CS207.
[CowdenV:11]
Stephen Cowden and Jans van der Woude: Reed-Elseviers 20-F report to the SEC,
for FY 2010; SEC Edgar-online, 2011.
[Cowen:09]
Tyler Cowen: Modern Principles of
Economics; Worth Publishers, 2009.
[Cowen:11C]
Tyler Cowen: Corporate Income tax as a share of Corporate profits; Marginal
Revolution, 17 Nov 2011. Nice Graphs. Corporate Tax should be zero. Used in Figure
AppG.3. <<from [CowenT:11] ??>>
[Cowen:11G]
Tyler Cowen: The Great Stagnation: How
America Ate All The Low-Hanging Fruit of Modern History, Got Sick, and Will
(Eventually) Feel Better; A Penguin eSpecial from Dutton [Kindle Edition] 2011.
In Kindle
[CowenT:11] Tyler Cowen and Alex Tabarrok: Modern Principles, Macro Economics, 2nd Ed.; Worth
Publishers, 2011. Easy reading, have. Low level
expectations. New Philosophy? Nothing on intangibles or taxhavens.
[Cox:11]
Patrick Cox: Taxmasters: We solve your Tax problems; <http://www.txmstr.com>, 2011.
[Coy:12]
Peter Coy: “The Problem with Patching Up the Tax Code”; BBW, 19 Nov.2012, pp.29-31. Tax expenditures. {VIC Ch10.6}
[Coy:13B]
Peter Coy: “In Job Creation, Big Is Often Better”; BBW, 15 Apr.2013, p.16. Big companies have more money to invest in growth, are
more global. {VIC Ch9.2}
[Coy:13E]
Peter Coy: “The Rise of the Intangible Economy”; BBW, 22 Jul.2013, pp.6-7. The BEA will add costs of generating IP, as R&D
and Movies to the GDP, increasing it by 2.7%. In 1977 tangible investment was
about 10% of gdp and intangible about 8%, in 2010 the estimates are 7% and 14%.
[CoyD:11] Peter Coy and Jesse Drucker: “Apple, Google May Profit
on a Tax Holiday”; Bloomberg Businessweek,
17 March 2011. Repatriation issues. Mentions formulary apportionment taxation.
[Cray:09] Charlie Cray: Obama's Tax Haven reform: Chump Change;
CorpWatch, 15 June 2009. {VIC Ch8.9}
[CremerG:97]
Helmuth Cremer and Fahrouz Gahvari: “Tax Competition and Tax Evasion”; Nordic Journal of Political
Economy, Vol.24, 1997, pp.89-104.
[CremerG:00] Helmuth Cremer
and Fahrouz Gahvari: “Tax Evasion, Fiscal Competition, and Economic
Integration”; European Economic Review, Vol.44, pp.1633-1657.
[Crichton:06]‡
Michael Crichton: Canada adopts the Anticipated Profits Approach for
Calculating a Reasonable Royalty Rate ; Canadian Intellectual Property Review,
24 CIFR, June 2006, pp.215-234. Author is with
Gowlingss, LaFleur Henderson LLP, Ottawa, Canada.
[
[CroninEa:11] Doug Cronin, Mike
Heimert, Robert Kirschenbaum, Charles Larson, and Irving Plotkin: “`Useful Life’
Determination in the Context of Intangibles Transfer Pricing Valuation Theoretical / Heuristic Framework for
Analysis (i.e., Not Driven by Regulations)”; NABE Transfer Pricing Symposium,
July 2011. —Boston Scientific,
—Ceteris, —Miller & Chevalier, —IRS, —PWC
[CroninLH:04] Bruce Cronin, Lesley Catchpowle, and
David Hall: “Outsourcing and Offshoring”; CESifo
Forum, a quarterly journal, Summer 2004, The IFO institute for Economic
Research and, Munich, Germany, www.cesifo.de, pp.17-21. Globalization.
[Crowell:37] Chester Theodore Crowell: “Our Tax Jungle”; Harper’s Magazine, Vol.175, Nov.1937. Quotes Morgenthau
on importance of fairness.
[CTJ:12] CTJ: Policy
Options to Raise Revenue; summary of [Wamoff;12] , Citizens for Tax Justice, 8
March 2012.
[Cunningham:13] Peter Cunningham: "A dark, cruel comedy
at the expense of the Irish taxpayer"; Financial Times, 27
Jun.2013, , p.9. Lack of banking
yregulations in Ireland and the guarantee provided to the Anglo-Irish bank
settles the Irish with abligations approaching Euro 30B.
[Cunningham:12] Peter Cunningham: Capital Sins; 2012. A
novel set during the Irish financial crisis , starting in 2008.
[Cusack:11] Bob Cusack: Gang
of Six Collapses: Winners and Losers; The Hill, 22 May 2011.
[Cusumano:95]†
Michael Cusumano and Richard Shelby: Microsoft Secrets, How the World's most
Powerful Software company Creates Technology, Shapes Markets, and Manages
People; MIT, 1995.
[Cyprus:11] Cyprus
tax: Taxation of Interest, Dividends and
Capital Gains in Cyprus;
<http://www.fbscyprus.com/assets/mainmenu/538/docs/INT%20-%20DIV%20-%20CAP%20GAINS.pdfl>
Dagan:00] Tsilly
Dagan (Bar Ilan School of Law): The Tax Treaties Myth; NYU Journal of International Law and Politics , Vol.32, Oct.2000,
p.939-996. <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=379181. On Double taxation. Alternatives, game theory. No tax
alternative example pp.955-957 . Implies corporate taxes throughout. No tax
haven. Many references. {VIC Ch8.6.3}
[Daily:02] Frederick
W. Daily III: Stand Up to the IRS;
Nolo, 2002.
Many numbers. Org chart Individuals only have an out-of-state family
corporation. Criminal div: 4500 people, IRS processes over 125 tax returns. 200
M filings, 25% auditors, 15% Collections = 40% of 92,000 = , 3% criminal
investigators. 57% operations [Daily:09]‡.
The Office of Tax Shelter Analysis (OTSA) in the LB&I Division collects and
analyzes information about abusive tax shelters and transactions, and
coordinates LB&I's tax shelter planning and operation. 1500 attorneys in
Office of the Chief counsel. 47,000 for
small business and self-employed. Only 290 in LMSB in DC, PA NY IL
TX CA.
[Dalio:09] Ray Dalio: A Template
for Understanding What Is Going On; in Insghts Into the Global Financial Crisis,
CFA institute, Research Foundation, 2009, pp.94-109. deleveraging
[Daly:11] Spencer Daly: “Secrecy
in Limbo: What the Most Recent Settlement With the IRS Means for UBS and the
Rest of the Swiss Banking Industry”; The
Journal of International Business & Law no.108, Hofstra Univ., 30 March
2011, pp.133-152. Swiss bank
shifting to Singapore and HongKong Subsidiaries.
[Damodaran:99] Aswath
Damodaran: “Research and Development Expenses: Implications for Profitabilty
Measurement and Valuation”; Stern School of Business, Working paper NYU Working Paper No.FIN-99-024. R&D cost should be treated as (tax
deductible) capital expenses. Putting IP on books was possible before 1975 in U.S.,
and under IAS 9.
[Damodaran:00]
Aswath Damodaran: ”An Updated Amazon
valuation”; working spreadsheet at <http://pages.stern.nyu.edu/~adamodar/amazon2000-1.xls.
[Damodaran:02]†Aswath Damodaran: The Dark Side of Valuation; Valuing
Old Tech, New Tech, and New Economy Companies; Prentice-Hall, 2002.
[Damodaran:03]
Aswath Damodaran: Measuring Company Exposure to Country Risk Theory and
Practice; SSRN-id889388.
[Damodaran:05] Aswath Damodaran: ” The Value of Control: Implications
for Control Premia, Minority Discounts and Voting Share Differentials”; S-DRP-05-02,
Stern School of Business , July 2005, Available at SSRN: <http://ssrn.com/abstract=837405; slides at <http://pages.stern.nyu.edu/~adamodar/pdfl>iles/country/controlvalue.pdfl>. Also: The Promise and Peril of Real Options; Stern School of
Business, Working paper S-DRP-05-02, July 2005, 75pp.<MISQ file> Focuses
on Options. Options have value to overcome uncertainty. Rarely valued, but
implicitly included in many acquisitions, and to a lesser extent in share
prices.
[Damodaran:06]
Aswath Damodaran: Damodaran on Valuation, 2nd edition;
New York: John Wiley and Sons, 2006.
[Damodaran:06D]‡
Aswath Damodaran: Dealing with Intangibles; Valuing Brand Names, Flexibility,
and Patents; Stern School of Business,
Jan.2006, 73pp.<MISQ file> Focuses on Options. Quotes Leonard Nakamura on
Investment in Intangibles $1trillion in 2000, and $6T. capitalized value.
(implies life?).
[DanowitzEa:12]
Andrew Danowitz, Kyle Kelley. James Mao, John P. Stevenson, and Mark Horowitz:
CPU DB: Recording Microproecessor History; CACM Vol.55 No.4, April 2012.
[DarbyL:07] Joseph B. Darby IIII and Kelsey Lemaster: Double Irish
More than Doubles the Tax Savings”; Practical
US/International Tax Strategies, WorldTrade Executive, Vol.11 No.9, 15 May 2007.
[dAroma:27] Pasquale
d’Aroma, chair Committee of Technical Experts on Double Taxation and Tax
Evasion: Double Taxation and Tax Evasion; League of Nations report G.261 M85, 1927.II. Geneva, April
1927, scanned and re-typeset by
Michel J. McIntyre, 8 Feb.2004 at the
University of Michigan. Section I,
Impersonal taxes Article 4.Income from
shares or similar interests shall be taxable in the State in which the real
centre of management of the undertaking is situated. Article 5.Income from any
industrial, commercial or agricultural undertaking and from any other trades or
professions shall be taxable in the State in which the persons controlling the
undertaking or engaged in the trade or profession possess permanent
establishments. ... The real centres of
management, affiliated companies, branches, factories, agencies, warehouses,
offices, depots, shall be regarded as permanent establishments. Should the
undertaking possess permanent establishments in both Contracting States, each
of the two States shall tax the portion of the income produced in its
territory.The fact that an undertaking has business dealings with a foreign
country through a bona fide agent of independent status (broker, commission
agent, etc.), shall not be held to mean that the undertaking in question has a
permanent establishment in that country. Should the undertaking possess
permanent establishments in both Contracting States, each of the two States
shall tax the portion of the income produced in its territory. Article 7. Salaries, wages or other
remuneration of any kind shall be taxable in the State in which the recipients
carry on their employment. Salaries of officials and public employees who are
serving abroad shall, however, be taxable in the State which pays these
salaries.
[DARPA:07]
DoD: Research, Deve,opment, Test, and Evaluation, Vol.1 Defense Advanced
Research Projects Agency; Budget, Feb.2007.
[DauchyN:09] Estelle Dauchy and Tom Neubig: "President Obama's
Business Tax Proposals: Industry Effects"; Tax Notes, 19 Oct. 19,
p. 314. Doc
2009-21147, or 2009 TNT 202-8 . Ernst & Young LLP
Quantitative Economics and Statistics calculations. U.S.-headquartered global companies pay a
little more than half of the total U.S. corporate income taxes. Quotes rules
for new Japan deduction.
[Daum:01] Juergen Daum: The New DASB rules for reporting in
Intangible Asset – The U.S. Versus the European way; The new New Economy Analyst Report, 10 Nov.2001. Scandinavian
countries report IP.
[Davidoff:11] Steven
M. Davidoff: DealBook: The Benefits of Incorporating Abroad in an Age of Globalization; The New
York Times, 20 Dec.2011. The successful
public offering of Michael Kors Holdings offers a case study on how
globalization increasingly allows companies to avoid taxes and regulation in
the United States. JPMorgan
Chase estimates that American multinationals have $1.375
trillion in cash sitting overseas. [ACM]
[Davidson:11]‡ Adam Davidson: “Can Anyone Really
Create Jobs?”; The New York Times, 3
Nov. 2011.
[Davidson:12]
Adam Davidson: “The Purpose of Spectacular Wealth, According to a Spectacularly
Wealthy Guy”; The New York Times, 1
May 2012. Preview of Conard, defending the 1%.
[Davis:09] Manny Davis:
Symantec Wins Tax case – Not responsible for IRS Back Taxes ;
BackTaxHelp.com , 11 Dec.2009, retrieved 11 Oct 2011. $545M savings. [xls/forest]
[DavisRKM:11] Benjamin Davis, Elizabeth Ridlington, Gary Kalman, and Jeffrey Musto: "Tax Shell Game: How much did Offshore Tax havens Cost you in 20102?"; U.S. Public Research Interest Group , 18 April 2011. http://www.uspirg.org/reports/usp/tax-shell-game-how-much-did-offshore-tax-havens-cost-you-2010>. Annual loss is $100B. Tax Evasion: Tens of Billions in Taxes Avoided Through Offshore Activity, Havens, U.S. PIRG Says.
[DavisM:97] Shelley L. Davis and Mary Matalin: Unbridled
Power: Inside the Secret Culture of the IRS. Harper Collins, 1997. ISBN 0-88730-829-5. Former IRS historian.
[DavydenkoSZ:12] Sergei A. Davydenko, Ilya A.
Strebulaev, and Xiaofei Zhao: , A Market-Based Study of the Cost of Default; to
appear, 2012. University of Toronto,
Rotman School of Management (D&Z), Stanford University, Graduate School of
Business, and NBER (S)
[deGrootE:11]
Gaby de Groot and Siem Eikelenboom: “Fiscale BV’S onder de loep genomen”; Het Financieele Dagblad,
19 Jan.2013. Problems with resolving Enron’s bankrupt shell operations in the
Netehrlands, Enron used Dutch rulings to avoid reporting. Chnges as of 2004.
But still, shells gew from 9000 in 2004 to 1400 in 2010. Dutch report due in
march/April 2013.
[DeHoon:12]
Iven de Hoon: Tax advice is our passion, our passion is your benefit; Brochure,
Antwerp, Belgium. 2012. Straightforward information on Hong Kong, Curacao, Isle of
Man, Luxembourg.
[delaVega:1668]
Joseph
Penso de la Vega: Confusión de Confusiones; 1668, reprint Wiley, 1996. The stock market, trading in shares of the second multinational, after the British East India
Company.
[DelMonte:10] James
Del Monte: IT Employer Information, Cost of Hiring/Turnover (CoH); JDA
professional Services, 2010, <http://www.jdapsi.com/Client/articles/coh. $48.5K direct, $204.5 indirect $253K.
[Deloitte:10] Deloitte: Uncertain Tax Positions and the IRS Transparency
Initiative, No Holds barred; Deloite Development LLC, 10 May 2010.
[Deloitte:11] Deloitte: SEC Compliance Checklist –
General; Deloitte TAX , Jan.2011. includes rules for significant subsidiaries, paperwork
reduction.
[deMatteis:99] Bob
deMatteis: From Patent to Profit: Secrets
and Strategies for the Successful Inventor; 3rd edition, Berkeley
Publishing, 1999. Profit and Royalty. Profit minimization is common already for taxes, so a
poor basis for royalty.
[deMooij:05]
Ruud Aloysius de Mooij: “Will Corporate Income Taxation
Survive?”; De Economist, Springer Verlag, Vol.153 no.3, Dec.2005, pp.277-301. Quotes Devereux: corporate taxes will
wither. taxing reduces risk if failure!
[deMooij:09]‡
Ruud de Mooij: "An applied analysis of ACE and CBIT reform in
the EU“; CPB
Discussion Paper 128, CPB Netherlands
Bureau for Economic Policy Analysis,
2009.
[deMooijE:08]‡
Ruud A. de Mooij & Sjef Ederveen, 2008. "Corporate Tax Elasticities A Reader’s Guide to Empirical Findings“; Working
Papers 0822, Oxford University Centre
for Business Taxation; Oxford Review of Economic Policy, Oxford University Press, Vol.24 no.4, Winter, pp.680-697.
[deMooijN:08] Ruud de Mooij and Gaëtan Nicodème: "Corporate tax policy and incorporation in the EU"; International Tax and Public Finance, Springer, Vol.15 no.4, Aug.2008, pp.478-498.
[deMooijN:08P]‡
Ruud A. De Mooij & Gaëtan J.A. Nicodème: How Corporate Tax
Competition Reduces Personal Tax Revenue;
CESifo DICE Report, IFO Institute for Economic Research at the University of Munich, Vol.6
no.1, April 2008, pp.27-31. Shift because shifting to corporate forms, LLCs.
[Demos:13]
Tilis Demos: “Twitter Saays Value May Top $11 Billin”; Wall Street Journal, 25
Oct.2013, p.1. [ACM].
[DengL:06] Z. Deng and Baruch Lev:
“In-process R&D, to Capitalize or Expense?”; The Journal of Engineering and Technology Management, March 2006,
pp.18-32. An
IPR&D charge may signal future earnings growth to investors. Deng and Lev
found that investors value the acquired R&D differently from goodwill. They
concluded that investors perceive, on average, the fair market values assigned
to IPR&D projects as credible indicators of asset values. A company with a
larger IPR&D charge is more likely to be rewarded by investors in
postacquisition periods.
[DengLN:99] Z. Deng, Baruch Lev, and Francis Narin:
Science and technology as predictors of stock market performance; Financial Analysts Journal, May 1999,
DeSanctis publishing, pp.20-32
[Denning:10] Steve Denning: The Leader’s Guide to Radical
Management; Jossey-Bass, Wiley, 2010.
have
[Denning:11]‡ Steve Denning: Why
Amazon Can't Make A Kindle In the USA; Forbes, 17 Aug.2011. The loss of
manufacturing skills comes after offshoring.
[Denning:11D]
Steve Denning: The dumbest Idea in the World: Maximizing Shareholder Value;
Forbes, 28 Nov.2011. Comment on[ Martin:11] book.
[Denning:12]‡ Peter Denning: “The Idea Idea”;
Communications of the ACM; Vol.55 No.3, March 2012, pp.30-32.
[Denning:12M]
Steve Denning: What Every Compamy Must Understand; Forbes, 8 Aug.2012. Comment on[
Rubin:13] Scrum book. “All firms are software firm nowe”
[Denning:13C]
Steve Denning: Did Ronald Coase Get Economics Wrong; Forbes, 25 Sep..2013. Now
we have the creative econmy. .Cites Andrew Hill (no, due to C-suite compensation,
Oligogolies, getting government breaks, finacial engineering, hiding low RoI), Vitari
(yes, diseconomies), Hagel (scalable learning, decentralize organizations
around employees, needs paradigm shift) , Roger Martin (distinguishes
algorithmic versus heuristic work – requring smarts, often from external
Sources)
[Denniston:11P]
Lyle Denniston: Argument preview: Corporate “personhood” – again; 18 Jan.2011. <http://www.scotusblog.com/2011/01/argument-preview-corporate-personhood-again/
[Denniston:11R]
Lyle Denniston: Argument recap: Losing on a privacy claim?: 19 Jan.2011. [<http://www.scotusblog.com/
?p=112356 [App.G?]
[Derman:04] Emanual Derman: My Life as a Quant; Wiley, 2004.
[Derman:11] Emanual Derman: Models.Behaving.Badly; Free Press, Simon and Schuster, 2011. Have on Kindle.
Intuition and experience.
[deRothschild:12] Evelyn Robert de Rothschild:
Monetary Express; The Huffington Post,
14 March 2012. Election financing.
[Desai:08]‡
Mihir A. Desai: Decentering of the Global Firm; Harvard University working
paper 09-054, Sep.2008. I used that in
chap 2 for inversion, now in Chap.9?
[Desai:09] Mihir
A. Desai: Securing Jobs or the New Protecionsim:: Taxing the Overseas
Activities of Multinational Firms; ; Harvard University working paper 09-107, 2009.
[DesaiD:07] Mihir A. Desai and Dhammika
Dharmapala: Taxes and Portofolio Choice: Evidence from JGTRRA’s Treatment of
International Dividends; NBER Working paper 13,281, July 2007. <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1000680.
[DesaiD:08]‡
Mihir A. Desai and Dhammika Dharmapala: Taxing the Bandit Kings; Yale Law
Journal Pocket Part 98, YLJO Essay, 17 Nov.2008. On sovereign wealth funds. SWFs are tax-exempt, but
still should not be taxed by the US per §829.
[DesaiH:00]
Mihir A. Desai and James R. Hines jr.:
"The Uneasy Marriage of Export Incentives and the Income tax"; Tax Policy and the Economy, Vol.15, MIT
press; National Bureau of Economic
Research, NBER working paper 8009, Nov.2000.
[DesaiFH:01] Mihir A. Desai, C. Fritz Foley, and James R. Hines jr.:
“Repatriation taxes and dividend distortions”; National Tax Journal, Vol.54 no.4, Sep.2001, pp.829-851.
[DesaiFH:03]‡
Mihir A. Desai , C. Fritz Foley, James R. Hines, Jr: "A
Multinational Perspective on Capital Structure Choice and Internal Capital
Markets“; NBER Working Papers 9715, National Bureau of Economic Research, Inc.,
2003. Other
versions: [DesaiFH04N]‡
[DesaiFH:04A]‡ Mihir A. Desai, C. Fritz Foley, and
James R. Hines Jr. "Venture Out Alone“; Harvard
Business Review 82 no.3 (March 2004).
[DesaiFH:04F] Mihir
A. Desai, C. Fritz Foley, and James R. Hines jr.: "The Costs of Shared Ownership: Evidence From International Joint
Ventures“; Journal of Financial
Economics 73 no.2, Aug.2004, pp.323-374.
[DesaiFH:04R]
Mihir
A. Desai, C. Fritz Foley, and James R. Hines jr.: "Economic Effects of Regional Tax
Havens“; NBER working paper 10806, SSRN No.601108 , Sep.2004. Nearshore
taxhavens, trading zones?. 20.8% tax reduction. Stimulates regional growth. Tax competition.
[DesaiFH:04S]‡ Mihir A. Desai, C. Fritz Foley, and James R. Hines
Jr. "A
Multinational Perspective on Capital Structure Choice and Internal Capital
Markets“; Journal of Finance,
Vol.59 no.6, Dec.2004, pp.2451-2488. (Revised version of NBER Working Paper
9715.)
[DesaiFH:04W]‡ Mihir A. Desai, C. Fritz Foley, and
James R. Hines Jr. "Foreign
Direct Investment in a World of Multiple Taxes“; Journal of Public Economics 88 no.12 (Dec.2004):
2727-2744. (This
paper is a revised version of HBS Working Paper 03-047 and NBER Working Paper no.8840.)
[DesaiFH:05D]
Mihir
A. Desai, C. Fritz Foley, and James R. Hines jr.: "The Demand for Tax Haven Operations“; Journal of Public Economics, Vol.90,
Elseviers, Feb.2006, pp.513-531; SSRN No.593546, March 2005.
Who
uses taxhavens?. Multinationals, companies with R&D. does not distinguish types
of taxhavens.
[DesaiFH:05E]
Mihir
A. Desai, C. Fritz Foley, and James R. Hines jr.: “Do Tax Havens Divert
Economic Activity?”; Economics Letters, Vol.90, Elseviers 2006, p.219-224.
[DesaiFH:05I]‡ Mihir A. Desai, C. Fritz Foley, and
James R. Hines Jr. "Foreign Direct Investment and the Domestic Capital Stock“; American Economic Review Vol.95 no.2, May
2005, pp.33-38.
[DesaiFH:06A] Mihir A. Desai, C. Fritz Foley, and James R. Hines
jr.: "Taxation and Multinational Activity; New Evidence, New Interpretations“; Survey of Current Business, Vol.82 no.6
Feb.2006, pp.16-22. Indirect foreign
taxes do not receive tax credit.
[DesaiFH:06E]
Mihir A. Desai, C. Fritz Foley, and
James R. Hines jr.: "Do Tax Havens Divert Economic Activity?“; Economics
Letters, Vol.90, Elseviers 2006,
p.219-24; also Ross School of Business Working paper Series no.1024S,
University of Michigan; SRN No.704211, April 2005. Increases FDI in other offshore activities.
[DesaiFH:07] Mihir A. Desai, C. Fritz Foley and James R. Hines jr.:
"Economic Effects of Dorgan, Levin, & Feingold, Deficit Reduction.
Senate Bill 110, Subtitle B, Section 212. R 25 Jan.2007. <check>
[DesaiFH:07L]‡ Mihir A.
Desai, C. Fritz Foley, and James R. Hines Jr. "Labor
and Capital Shares of the Corporate Income Tax Burden“; in Who Pays the Corporate Tax in an Open
Economy?, Brookings, Dec.2007. 45-75% falls on
labor.
[DesaiH:00] Mihir A. Desai
and James R. Hines Jr.: "The Uneasy Marriage of Export Incentives
and the Income tax"; Tax Policy and
the Economy, Vol.15, MIT press;
National Bureau of Economic Research, NBER working paper 8009, Nov.2000.
IC-DISC and
FSC, tax credit, Subpart F: passive income of CFCs is deemed distributed.
[DesaiH:04] Mihir A. Desai and James R. Hines jr.: “Old Rules and New Realities: Corporate Tax Policy in a Global Setting”; National Tax Journal, Vol.57 no.4, Dec.2004, pp.937-960.
[DeToqueville] Alexis
de Toqueville: Democracy in America; On Kindle
[Deutsch:08] R.
Deutsch, R. Arkwright, and D. Chiew: Principles and Practice of Double Taxation
Agreements: A Question and Answer Approach; BNA International, London, 2008.
[DevereuxGK:03]‡ Michael Devereux, Rachel Griffiths, and Alexander Klemm: Can
international tax Competition explain Corporate Income Tax reforms?; .Compute effective tax rates (EMTR) as tax paid over
earnings. Still based on reported taxable earnings.
[DevereuxH:03]
Michael P. Devereux
and R. Glenn Hubbard: "Taxing Multinationals"; International Tax and Public Finance, Springer, Vol.10 no.4, Aug.2003, pp.469-487. Formal model shows
that worldwide taxation is not optimal even with credits and deductions if
foreign taxes are high, but not if low, as in taxhaven. Deferral is limited and
is at full rate.
[DevereuxK:09]
Michael Devereux
and Christian Keuschnigg: Distorting the Arms-length principle ; Oxford University
Centre for Business Taxation, Working Paper 09/10 , July 2009. “arm’s length prices systematically differ from independent
party prices”
[DevereuxL:10] Michael Devereux and Simon Lorentz: Evaluating Neutrality
Properties of Corporate tax reform; Oxford University Centre for Business
Taxation, Working Paper 10/07, 12
April 2010. Single market rate versus international
loss?
[DevereuxL:11] Michael Devereux and Simon Lorentz:
How would EU corporate tax reform affect US investment in Europe; National Bureau of Economic Research, NBER working
paper 17576, Oct.2011. Many tables:
various industries effective tax rates (EMTR). Rank China 22.48, Korea
19.8%Japan 36%, Canada 25.7% US 34.98, India 29.5Germany 27% UK.26.3%. Still based on reported taxable earnings.
[Dey:89] Richard Morris Dey: In the Way of Adventure: The Story of
John Caldwell and Palm Island;
Offshore Press, 1989, 35pp.Out of print.
[Dharan:02] Bata G. Dharan: Enron’s Accounting Issues – what we can
learn to Prevent Future Enrons; Testimony prepared to US House Energy and
Commerce Committee’s Hearings on Enron’s Accounting, Feb.2002.
[DharmapalaH:06] Dhammika Dharmapala and
James R. Hines jr.: Which countries became Tax Havens? National Bureau of
Economic Research, 2006, Cambridge; revised May 2009.
[Dharmapala:08] . Dhammika Dharmapala: “What
problems and opportunities are created by tax havens?”; Oxford Review of Economic Policy, Oxford University Press, 2008.
[DharmapalaFF:09] Dhammika Dharmapala, C.
Fritz Foley, and Kirstin J. Forbes: `Watch what I do, Not what I say’: The
unintended Consequences of the Homeland Investment Act; NBER working paper
15023, June 2009. HIA is an alternate for the AJCA.
$300B repatriated the same amount paid out in dividends.
[DiamondZ:08] John W. Diamond and George R. Zodrow (eds): Fundamental Tax Reform: Issues, Choices and Implications; MIT Press, 2008. Foreword by James Baker III. Have.
[DickinsNW:05] Denise Dickins, Thomas G.
Noland, and Kenneth M. Washer: “Primer on Partnership-Compensation Models”; The CPA Journal, Aug.2005.
[Dijkstra:72]†
O. J. Dahl, E. W. Dijkstra, and C. A. R. Hoare, Structured Programming, Academic Press
1972.
Dingh:10] Leuyen Dingh: Transfer
Pricing: IRS Disagrees With Tax Court's Findings, Legal Interpretations in
'Veritas' Ruling; BNA Daily Tax Report, 12 Nov.2010.
[DinopoulosT:99]
Elias Dinopoulos & Peter Thompson:. "Scale effects in Schumpeterian models of economic
growth“; Journal of Evolutionary Economics, Springer, Vol.9 no.2, , 1999, pp.157-185.
[DinopoulosS:99]
Elias Dinopoulos, and Paul Segerstrom:
"The dynamic effects of contingent tariffs“; Journal of International Economics, Elsevier, Vol.47 no.1, , Feb. 1999, pp.191-222.
[Dionne:12]
E.J. Dionne: Ideological Hypocrites; The
National Memo, 20 Feb.2012. Earmarks and bailouts.
[Ditmer:11] Philip Dittmer: "U.S. Corporations Suffer High
Effective Tax Rates by International Standards"; Tax Foundation Special Report No.195, Sep.2011.
[Doebele:04] Justin Doebele: “Flex Forward: Flextronics' Michael
Marks says that outsourcing can only get much, much bigger”; Chief Executive, 1 July 2004.
[Doernberg:08]
Richard L.
Doernberg: International Taxation in a Nutshell, 8th edition;
Thomson West Law, 2008, 612pp.On Kindle
[Doggart:02] Caroline Doggart: Tax Havens and
Their Use; Economist Intelligence Unit, 2002. Quotes Powell defintiom.
[Dohmen:09] Joep
Dohmen: “Multinationals betalen vrijwel geen belasting”; NRC Handelsblad,
21 Feb.2008, updated 25 Nov.2009, <http://www.nrc.nl/economie/article1855259.ece/Multinationals_betalen_vrijwel_geen_belasting. <not a great reference>
[DoJ-TD:11]‡
Tax Division: About Us; US Government, Department of Justice, 2011. <http://www.justice.gov/tax/about_us.htm. tax division,
350 attorneys. Vacant leadership. codified at 28 C.F.R. § 0.70. On June 10, 1933,
President Franklin D. Roosevelt issued an executive order consolidating within
the Department of Justice the control of all federal tax litigation.
[DonadioP:11] Rachel
Donadio and Elisabetta Povoedo: “Italy Tries Raising the Social Stigma on Tax
Evaders”; The New York Times, 24
December 2011. $150B annually lost, underground economy is 17.5% of GDP.
[Donmoyer:10] Ryan J. Donmoyer: IRS Trims Demand for Corporate Tax-Shelter Lists - Businessweek, Sep 24, 2010. www.businessweek.com/.../irs-trims-demand-for-corporate-tax-shelters...,
– The U.S. Internal Revenue Service scaled back its
requirement that companies begin listing all tax-saving transactions to help
the agency.
[Dooley:11] Brian Dooley: International Taxation in America; Authorhouse, 2010. Non-professional
writing.
[Dorgan:07] Dorgan
et al.: US senate Deficit Reduction Bill of 2007, Senate Bill 681, Subtitle B,
S. 212, 110th Cong., 1st Sess. 2007. Radical changes of legislation are being proposed to
change taxation rules for CFCs both within countries, as the U.S., and among
OECD members.
[DossaniK:??] Rafiq Dossani and Martin Kenney: “The
relocation of Service provision to Developing Nations, The Case of India”;
pp.193-217. Year?
[DoT:07] Department of the Treasury: Treasury Conference on
Business Taxation and Global Competitiveness; background paper, 23 Jul.2007, 54pp.<http://www.treasury.gov/press-center/press-releases/Documents/07230%20r.pdf>. Cites CBIT. Us 13. 4%, OECD 16.1% 2000-2005
average
[DowdMM:12] Tim
Dowd, Robert McClelland, and Athiphat Muthiacharoen: New Evidence on the Tax Elasticity of Capital
Gains; Joint Committee on Taxation. June 2012, JCX 56-12, 49pp. pass through capital gains are highly
sensitive to persistent tax changes, not mutal funds
[Doyle:85]
Jon Doyle: “Reasoned Assumptions and Pareto Optimality”; Proceedings of IJCAI195, American Association for
Artificial Intelligence, 1985. pp.87-90..
[DoyleFT:09]†
John Doyle, Bruce Francis, and Allen Tannenbaum: Feedback Control Theory;
MacMillan 2009. Prior edition 1992, now available free on Google.
[Drucker:73]‡
Peter Drucker: The Practice of Management;
1973. There is only
one valid definition of a business purpose: to create a customer.
[
[..[ACM].
<http://www.businessweek.com/technology/google-tax-cut/google-terminal.html> ..[ACM].
..[ACM].
[
..[ACM].
..[ACM].
DuhiggB:12] Charles
Duhigg and Keith Bradsher: How the U.S. Lost Out On iPhone Work, Apple’s
Experience Shows Why Jobs Are Flowing to China; The New York Times, Economic View 22 Jan.2012. [ACM]
[DuhiggK:12] Charles
Duhigg and David Kocieniewski: How Apple Sidesteps Billions in Taxes; The New York Times, 28 April 2012. [xls/forest] [ACM]
[DukeU:13] Simon Duke and Jon
Ungoed-Thomas: “Google insider exposes ‘immoral’ tax scam”; The Sunday Times, 19 May 2013. Barney Jones: UK deals were booked in Dublin..[ACM].
[Dumagan:95] Jesus
C. Dumagan: Examining the Cost-Effectiveness of the Research and Experimentation
Tax Credit; Office of Business and Industrial Analysis, US Department of
Commerce, June 1995. Corporate R&D spending increased by $2 for every $1 tof
tyax credit. Excludes work done outside the US governmental sponsored research,
and social sciences research. [xls/taxexpenditures]
Greenlining
Institute Report Looks at Effects of Corporate Tax Havens; Corporate Counsel Magazine, 29 July 2011. Based on [KangN:11] report
. data on
repatriation sources, subsidiearies companies. Used Federal contract obligations can be
found at USA Spending, www.usaspending.gov NNNNN
[DunneHT:96]
Timothy Dunne, John Haltiwanger, and Kenneth R. Troske: "Technology and Jobs: Secular Changes and Cyclical Dynamics“; NBER
Working Papers 5656, National Bureau
of Economic Research, Inc. , 1996. ; Working
Papers 96-7, Center for Economic
Studies, U.S. Census Bureau; Carnegie-Rochester
Conference Series on Public Policy,
Elsevier, Vol.46 no.1), pp.107-178, June.
[DuPont:79] E.I. DuPont de Nemours & Co. v. United States, 608 F.2d 445 (Ct. Cl.1979). The basis for use of the Berry ratio.
[Durden:10]
Tyler Durden: HR 2487 = Capital Controls Act (Read Subtitle A—Foreign Account
Tax Compliance); 29 March 2010 , http://www.picassodreams.com/picasso_dreams/2010/03/hr-2487-capital-control-act-read-subtitle-aforeign-account-tax-compliance.html.
[DurlaufB:08] Steven N.
Durlauf and Lawrence E. Blume: The New
Palgrave Dictionary of Economics, 2nd edition” ; 8 Vol.set,
Palgrave MacMillan, 2008; also available on-line at <http://www.dictionaryofeconomics.com>. Extremely
technical.
[DurstC:03] Michael C. Durst and Robert E. Culbertson: Clearing
Away the Sand: Retrospective Methods and Prospective Documentation in Transfer
Pricing Today; Tax Law Review, Lexsee 57 Tax L. Rev.37, NYU School of Law, Fall
2003. 1985-1986
tax reforms. (King & Spalding, LLPI
[Dwoskin:12] Elisabeth Dwoskin: “The Incrementalist”; Bloomberg Businessweek, 11 June 2012. Long article on
Howard Marlow, president of the American League of Lobbyists. History of
lobbying. 1029 members 2011 spending $3,32B.
[Dwoskin:12D]
Elisabeth Dwoskin: “Defender of Last Resort”; Bloomberg Businessweek, 9 April 2012. Long article on Nina Olson, the national
taxpayer advocate. Focus on individual tax returns.
<http://insight.kellogg.northwestern.edu/index.php/Kellogg/article/cost_sharing_agreements
[http://www4.gsb.columbia.edu/filemgr?file_id=72157>In this section, we observe that when the taxpayer elects
to have the sub make a sequence of royalty payments, the taxpayer has an
incentive to overstate its projections of the sub.s post buy-in sales. In
contrast, when the taxpayer elects to have the sub make a lump-sum payment, we
observe that the taxpayer has an incentive to understate the sub.s post buy-in
sales
[Dyson:12] George Dyson: Turing’s Cathedral, The Origins of the
Digital Universe; Pantheon, 2012.
[E:09]
Lean Startup: Debunking Myths of Entrepreneurship; Stanford Video
4:28min 30 Sep 2009.
[E&Y:xx]
Ernst & Young License Agreement Library.
[EatwellMN:89]
John Eatwell, Murray Milgate, and Peter Newman (eds.): Money; The New
Palgrave; W.W. Norton Publishers, 1989.330pp. Excerpt of a 4-Vol.Dictionary of
economics. About 40 entries, most around 5 pages, Friedman has 40 pages. Classical macroeconomics”.
[EatwellEtAl:89]
John Eatwell et al. (eds.): Finance:
The New Palgrave; W.W. Norton
Publishers, 1989.Excerpt of a 4-Vol.Dictionary of economics. 1300 entries. Classical macroeconomics”. Recent The fall and rise of Keynesian Economics?
2011“ 25
books total.
[Ebert:11} Natalie Ebert: Netherlands Antilles;
<http://www.lowtax.net/comments/Hello_everybody_10690.html>
[EC:01]
European Commission:. "Company Taxation in the Internal Market“; Taxation
Studies 0005, Directorate General
Taxation and Customs Union, European Commission. , 2001.
[EcclesEa:01]
Robert G. Eccles, Robert H. Herz,
E. Mary Keegan,
David M. H. Phillips: The Value Reporting Revolution:
Moving Beyond the Earnings Game; Price-Waterhouse-Coopers, 2001.
[Eccher:95]
E. Eccher, The value relevance of capitalized software development costs;
Northwestern University, Kellogg School of Management, Evanston, IL, 1995:.
[Economist:00G]
Economist Gimme Shelter. Survey, The
Economist. (2000, Jan.27).
[Economist:
06P] The Economist: “Getting a Grip on Prosperity”; The Economist, 4 March 2006, p.72.
[Economist:07P]
Economist:Jeanne Roams: Places in the
Sun. The
Economist. (2007, Feb.2). Globalization.
[Economist:11G]
The Economist: GDP forecast; The Economist, 11 July 2011. Fig in references
Economist:11L]
Economist: “Money and Politics”; The Economist, 1 Oct.2011. Lobbyists are
effective: $1 spent on lobbyists for the AJCA returned $220 in repatriation benefits.
[Economist:11O]
The Economist: Owe Dear; The Economist, 18 July 2011. International Debts, Fig in references
[Economist:11S] Economist: Unsettling Wall Street; The Economist, 3 Dec.2011. Loss of
transparency in settlements <chapter
10>.
[Economist:11T] Economist:
Marginal Revolutionaries; The Economist,
31 Dec.2011, pp.51-54. The variety of macro-economic theories being pushed in
blogs.
[Economist:12A] Economist:
“Over-regulated America, The home of laissez-faire is being suffocated by
excessive and badly written regulation”; The
Economist, 18 Feb 2012. The focus here is on the Dodd-Frank bill derived
regulations, but has broad applicability.
[Economist:12C]‡
Economist: “Cracking the penal code”; The
Economist, 25 Feb.2012. Trade secret protection of IP.
[Economist:12E]‡
Economist: “The end of cheap China; The Economist, 20 Mar.2012.
[Economist:12D]
Economist: A Useful Trim; Economist,
25 Feb.2012. Obama’s tax plan and corporate tax rates. 35-> 28, with state taxes
39.6 -> 32.6$ cost $700B over 10 years, permanent R&D credit $250B over
10 years. Keep domestic credit. In the end the total effect is 26->25% tax
rate.
[Economist:12S] Economist: They sell sea shells, The
companies that form companies are a shadowy world and (see article) a thriving industry; Economist, 7 Apr.2012. Profiting from bilateral treaties. With
Tax havens extract, [Economist:13F]
[Economist:12T] Economist: Another
Game of Thrones; Economist, 1 Dec.2012.
Google,
Apple, facebook and Amazon.
[Economist:13]
Economist:
Tax havens, The missing $20 trillion, How to stop companies and people dodging
tax, in Delaware as well as Grand Caymans; Economist
special report, 16 Feb.2013. Ten articles: Storm survivors;
Enduring charms;
The good, the bad and the Ugland; Not a palm tree in sight;
Automatic response;
The price isn’t right;
The merry enablers;
Rise of the midshores;
Who’s the criminal?;
Sunshine and shadows.
Excellent bibliography.
[Economist:13C] Economist: After the personal computer; The Economist, 6 Jul.2013, pp.60-61. Useful
quantitative data about the PC industry, Taiwan, China, and the move to mobile.
[Economist:13M] Economist: plumbers in suits; The
Economist, 6 Jul.2013, pp.63-64. Markit, a company
controlled by banks, serving banks. Tried to buy LCH.Clearnet in 2011.
[Economist:13P] Economist : “The
new American capitalism_ Rise of the distorporation; The Economist, 26 Octl.2013, pp.63-64.
The rise of Master Limited Partnerships, which are able to circumvent rules
placed on cporoporations. Another reason for abloshing corporate taxation [Ch10.5]
[, pp.100-127
[Edgar:10] U.S. Securities and Exchange Commission: Company
Search; <http://www.sec.gov/edgar/searchedgar/webusers.html>, updated
11Feb 2010.
[EduardoNO:13] Tome Eduardo, Iuliia Naidenova and Marina Oskolkova: Millionaires and Intellectual
Capital: an Empirical Study; Universidade Lusiada Famalicao, Portugal, and Higher School of Economics
University, Perm, Russia, 5th European
Conference on Intelectual Capital, Bilbao, April 2013.
[Edvinson:02]
Leif Edvinsson: Corporate Longitude; Financial Times Prentice Hall
,
July 2001. “links the value of Human and Intellectual capital into measurement
and economic results” Finacial coinformation is only one dimension
(latitude). Leif is at Skanda and a professor of Intellectual Capital at Lund
university, Sweden.
78 percent of Dow’s 7,800-page U.S. tax return relates to the rules on foreign income. Has 1993-2003 corp taxrates.Uses unweighted averages.
[Eggers:13] Dave Eggers: The Circle; Knopf, 2013. A novel about big data. An over-the-top
takeoff on Google and beyond, focusing on privacy implications.
[EichelbergerB:12] Curtis
Eichelberger and Charles R. Babcock: “Watch a Game, Get a Write-Off”; BBW, 5
Nov.2012. A $100M tax
expenditure since 1986, helps fund stadiums.
[EikelenboomDG:11] Siem Eikelenboom and Gaby de Groot: “Nederland in Trek
bij Multinationals”; Het
Financieele Dagblad, 12 Sep.2011; and subsequent articles. Gains are Euro
1,5Mrd in 2007 according to DNB. Multiple stories. 28 sep 2011Shell has 523
subsidiaries. Extractive industry transparence initiative. EITI [xls/taxhavens]
[Eisenberg:97] Rebecca S. Eisenberg (chair): Intellectual Property Rights and Research Tools in Molecular Biology; National Academy Press, 1997.
[Elmendorf:11 ] Douglas W. Elmendorf: Reducing the Deficit: Spending and Revenue
Options; Congressional Budget Office, Congress of the United States, Mar.2011,
182–83. <http://www.cbo.gov/ftpdocs/120xx/doc12085/03-10-ReducingTheDeficit.pdf.>. [xls/Taxexpenditures]
[ElitzurM:96]
Ramy Elitzur and Jack Mintz: “Transfer Pricing Rules and Corporate Tax
Competition”; Journal
of Public Economics,Vol.60 no.3, 1996,
pp.410-422.
[Elias:11] Christopher
Elias: MF Global and the great Wall St re-hypothecation scandal; Thomson Reuters News & Insight, 12
July 2011. Earlier in Thomson
Reuters’ Business Law Currents,
alter,
you’re right on target regarding the founders, but metaphors aside, money is
not speech. Especially in a world that includes the Internet and
volunteers, it’s entirely feasible to put a strict limit on campaign spending
across multiple organizations. And whether or not a corporation is a person, it
absolutely isn’t a citizen, and we explicitly ban non-citizens from political
speech to sway campaigns. So the infrastructure already exists to limit
any of these corporate entities the way we’d limit a Chinese millionaire.
Elliott:12] Amy Elliott: International Practice Networks Differ
from Issue Practice Groups, Danilack Says; BNA Daily Tax Report, 4 Oct..2012.
[Ellis:77]
Arthur K. Ellis: Elementary Social
Studies, 6th edition; Allyn & Bacon 1977. Source for some
quote.
[Elsayyad K:11] May Elsayyad and Kai A.
Konrad: Fighting multiple tax havens. Journal of International Economics, 2011.
[Engle:96] L. Eric Engle: Law
and Economics; J. Jurispridence,
Elias Clark, Australia publ., Vol.32,
2009, p.61. Sect. III.critiques [Posner:81] .
Based on [Sulivan:10] Tax Notes.
[EntinM:12] Stephen Entin
and Will McBride: Simulating the Economic Effects of Romney’s Tax Plan; Tax
Foundation Fiscal Fact No.330, 3 Oct.2012. http://taxfoundation.org/article/simulating-economic-effects-romneys-tax-plan. Data in HMAT [xls/taxproposals]
[Erb:13]
Kelly Phillips Erb: “How Twitter Hopes to Reduce Its Tax Bill (in 140
charckters or less”; Forbes, 19
Oct.2013. [ACM]
[Erlich:94]
Jacob Erlich: "Royalty Rate Basics for U.S. Transactions"; Les Nouvelles, Licensing Executive
Society, June 1964, pp.86-88. See <http://www.lesi.org/Article/Les_Nouvelles_Online.html>
[Erlich:04]
Jacob N. Erlich (Boston, MA): "Buy-in Basics for U.S. Transactions"; Les Nouvelles, Licensing Executives
Society, http://www.lesi.org/Article/Les_Nouvelles_Online.html, Jun.2004,
pp.86-88.
[Ernst:05]‡
Dieter Ernst: “Complexity and Internationalisation of Innovation - Why is Chip
Design Moving to Asia?”; International Journal of Innovation Management, Vol.9,
No.1, March 2005.
[Estevez:05]
Valentin Estevez Rios: Liberals, conservatives, and your tax return, partisan politics and the enforcement activities of the IRS;
University of Chicago, 2005. Differences in audit rates
under democratic versus Republican administrations.
[Etzioni:84] Amitai Etzioni: Capital Corruption: The New Attack on American
Democracy; Harcourt Brace Jovanovich, March 1984, snd printing 1995.
[Etzioni:86] Amitai Etzioni: "Tax Evasion and Perceptions of Tax Fairness: A
Research Note"; The Journal of Applied Behavioral
Science, Vol.22 no.2, 1986, pp.177-185.
[Etzioni:87] Amitai Etzioni: "Corporations on the Government Gravy
Train";
Business and Society Review, No.62, Summer 1987, pp.4-10.
[Etzioni:89] Amitai Etzioni: "Label 'Em Hazardous: Economic Forecasters Are
In Deep Voodoo"; Washington Journalism Review,
Vol.11, No.5, June 1989, pp.39-41. Also published in Futures Research
Quarterly, Spring 1991, Vol.7, No.1, pp.31-35.
[Etzioni:10E]
Amitai
Etzioni: "The Great Entitlement Raid."; Society.,
Vol.47 no.4, July 2010. pp.81-285.
[Etzioni:10D] Amitai Etzioni: "Is Transparency the Best Disinfectant?"; Journal
of Political Philosophy, June, 2010.
Proposal for a Council Directive amending Directive
2003/48/EC on taxation of savings income in the form of interest payments; 23
Nov.2008.
[EU:10]‡
[Everson:11] Mark W.
Everson: “Lawyers and Accountants Once Put Integrity First”; The New York
Times, 18 June 2011. See [Barnes:11]
[EzraitiMcM:12]‡ Lester Ezrati and John N. McMullen: Statement to Congress; Senior Vice Presidents Hewlett-Packard Company, Permanent Subcommittee on Investigations, U.S. Congress, 20 Sep.2012. HP has 320,000 employees, 80,000 in US. 10.3B us wages. $3.3B R&D, 2/3 in US. ETR 21.2% 656 role of alternating short term loans. $1.9B average. 9% of capital. Rule avoisds BCC Belgian coordination center is its bank, also has a similar Cayman subsidiary. Reasons fro indefintly reinvested. Indefinte reinvestment APB 23 temporay outside basis differences, has an exceptions. Section 956.
[F ... ] are references to Appendix F, Formulas in
[W:13] Gio Wiederhold: Valuing Intellectual Capital, Multinationals and
Taxhavens; series Management for Professionals, Springer Verlag, New York, to
appear 2013.
[FaderHH:03]†
Peter S.Fader, Bruce G.S. Hardie, Chun-Yoa Huang: A Dynamic Changepoint Model
for New Product Sales Forecasting; Wharton School of Business, Univ. of
Pennsylvania, On-line reports, July
2003.
[Faiferlick:01]
Christopher J. Faiferlick: Transfer Pricing of Computer Programs; Chapter 45 in
[Feinschreiber:01] Transfer Pricing Handbook, 3rd Edition, Wiley, 2001.
[Faiferlick:06] Chris
Faiferlick, Robert Miall, And Paul Balkus: Response of members of Ernst &
Young’s Global Transfer Pricing Team to the OECD’s Invitation to Comment on
Transactional Profit Methods; OECD, Paris, 2006. In [OECD:06] In OECD:
TransactionalProfitMethods-ResponsesToTheOECD InvitaiontoComment.
[Fallon:12] Padraic Fallon;
(ed):; Euromoney magazine. On iPad
[FamaF:98]
E.F. Fama, and K.R. French: “Taxes, Financing Decisions and Firm Value”;
Journal of Finance 53, 1998, pp 819-843. Data 1963 to
1998, found that companies that paid dividends provided a higher rate of
return. (7.8 % versus 5.4%) than those companies that did not pay dividends.
[FarhangDR:07]
Ali R. Farhang, Tim Deeter, and Sunit Rikhi: “Co-optimization of Product Design
and Semiconductor Process Technology: The Core of a Winning DFM Strategy”; Future Fab International, Vol..22,
Chapter 3, 9 Jan. 2007. Design for Manufacturability, Intel’s Tick-Tock approach to the
synchronizationof the life cycle.
Received from Gupta, Intel Oregon `Fabless does only Tock, using existing
libraries’.
[Farrell:12] Maureen Farrell: “Calpers: We’re getting even more activist”;
CNNMoney, 2 May 2012.
[FarrellKS:05] Diana Farrell, Noshir Kaka, and Sascha Stürze:
“Ensuring India's offshoring future”; McKinsey Quarterly, Sep.2005. <200,000 jobs gained
2004 by Indian NAS&S companies>
[FASB:85] Financial
Accounting Standards Board: Accounting
for the Costs of Computer Software to be Sold, Leased, or Otherwise Marketed
- FAS 86; 1985. The capitalization of external use software development
costs is required once functionality is demonstrated. Customer maintenance and
support costs for computer software should be expensed when related revenue is
recognized or when those costs are incurred, whichever occurs first, <but
not as R&D-gio> From [LevS:96] In 1985 the FASB made an exception to the
full expensing requirement for some software development costs, see FAS No.86
(Eccher, 1995). In several other countries R&D capitalization is allowed
and even required. For example, in the UK, SSAP 13 requires that expenditures
on pure and applied research should be written off as incurred, but development
expenditures may, in certain defined circumstances, be deferred to future
periods. The Canadian Standard (section 345 of the CICA Handbook) goes
further to require the deferment of certain development expenditures. The
International Accounting Standard, IAS 9, is generally in line with the
Canadian standard with respect to R&D capitalization.
[FASB:01]
Statement 142: Annual statement required re impaired intangibles <what is
included> and goodwill – no longer based on a fixed amortization schedule, [Chap
3] [Martin:11, 620] . Used to match Intangibles to
market cap, what is included?
[FASB:04] Financial Accounting Standards
Board: Disclosures About Intangible Assets, Removal of Project on recognition
of unrecognized intangibles; Financial Accounting Foundation, 21 May 2004.
[FASB:05]
Financial Accounting Standards Board: Practical
Accommodation to the Application of Grant Date as Defined in FASB Statement No.123(R);
FAS 123(R)-2, Financial Accounting Foundation, 18 Oct.2005.
[FASB:09] Financial Accounting Standards Board: Accounting
Standards Codification, version 3; Financial Accounting Foundation, 2009. Not
applicable as a basis for income tax determination. Formalizes intra-entity.
[Faux:11]
Jeff Faux: America’s Trade Policy of the Absurd; The American Prospect, 7 Feb.2011.
[FeenstraH:04]
Robert C. Feenstra and Gordon H. Hanson:
Global production sharing and rising inequality: A survey of trade and
wages; in [ChoiH:03] , pp.146-185. Strongly suggests that globalization has contributed
significantly to income inequality.
[FeenstraEa:10] Robert C. Feenstra et al.: Report on the Sate of
Available Data for the Study of International Trade and Foreign Direct
Investment; National Bureau of Economic Research, Working paper 16254, Aug.2010.
[FeenstraMRS:09] Robert C. Feenstra, Benjamin Mandel, Marshall B.
Reinsdorf, and Matthew Slaughter: Effects of Trade Gains and Tariff Changes on
the Measurement of U.S. Productivity Growth; NBER working paper No.15592, Dec.2009,
also working paper, Univ. of California, Davis , March 2008.
[Feinschreiber:01] Robert Feinschreiber: Transfer Pricing Handbook, 3rd edition;
Transfer Pricing Consortium, John Wiley Publishers, April 2001.
[Feinschreiber:04]
Robert Feinschreiber: Transfer Pricing Methods: An application Guide; Wiley,
2004. There
has never been an easy-to-use and convenient book that addresses salient and
fundamental transfer pricing issues . . . until now. Designed to specifically
assist mid-sized businesses facing transfer pricing issues now and in the
future, Transfer Pricing Methods is a comprehensive guide that provides
in-depth coverage of various transfer pricing methods and applications that are
available to today's mid-sized corporations. An invaluable reference for all
tax managers, CEOs, and CFOs, Transfer Pricing Methods provides a practical
focus on the techniques available and their consequences. Featuring
contributions from industry experts, complete coverage includes: Comparable
profits methods Cost sharing Transactional net-margin method Adjustments of interest rates Resale price techniques Benefiting from the
cost-plus method Market share Organisation for Economic
Co-operation and Development guidelines Life-cycle analysis Use of
multiple-year data.
[Feldstein:13] Martin
Feldstein: A Simple Route to Major Deficit Reduction; Wall
Street Journal, 20 Feb.2013. Cap deductions at 2%. Critcal comments.
[FeldsteinHH:95] Martin Feldstein, James R. Hines Jr. and R. Glenn Hubbard (eds.): Taxing multinational corporations;
University of Chicago Press, 1995. Collection of analytical papers. Have
[FeldsteinHH:95-1]
Martin Feldstein, James R. Hines Jr. and R. Glenn Hubbard eds.: The effects of taxation on multinational
corporations; Chicago: University of Chicago Press, 1995. HD2753.A333 ISBN
0-226-24094-9.
[FeldsteinS:78]
Martin Feldstein and Joel Slemrod:
"Inflation and the Excess Taxation of Capital Gains on Corporate
Stock"; National Tax Journal Vol.31, 1978, pp.107–118;
[FentonP:92]† Norman E. Fenton snd, Shari Lawrence Pfleeger: Software
Metrics; Less (11 pages, 3 pages
of criticism: 15, 97,148,259-265, 326, 413-414, 453) on Function Points. See
FentonPages.jpg.
[Fernandez:09]
Pablo Fernandez: “Market Risk Premium Used in 2008 by Professors: A Survey with
1,400 Answers”; SSRN <http://ssrn.com/abstract=1344209, IESE Business
School. Madrid. Spain.
[Fernandez:10]‡ Pablo Fernandez: Equity Premium: Historical, Expected,
Required and Implied; IESE Business School, Univ. of Navarra, Spain; SSRN
eLibrary, <http://ssrn.com/paper=1609563, 2010.
[Fernandez:12C]
Pablo Fernandez: Ten Badly Explained Topics in Corporate Finance Books; IESE
Business School, Univ. of Navarra, Spain 25April 2011; SSRN: http://ssrn.com/abstract=2044576. WACC and family.
[Fernandez:12D]‡ Pablo Fernandez: Valuing Companies by Cash Flow Discounting: Fundamental
Relationships and Unneccessary Complications; IESE Business School, Univ. of
Navarra, Spain Spain;, SSRN eLibrary, <http://ssrn.com/paper=2117765, 2012.
[Fernandez:13] Pablo
Fernandez: Valuation and Common Sense;
IESE Business School, Univ. of Navarra, Spain, SSRN eLibrary, 2013, <http:// http://ssrn.com/abstract=2209089>.
[Fernandez:13Y] Pablo Fernandez, 1,959 Valuations of
the YPF Shares Expropriated to Repsol; IESE
Busi-ness School, Univ. of Navarra, Spain 1 Mar.2013:, SSRN: <http://ssrn.com/abstract=2084213>.
[FernandezAA:11] Pablo Fernandez, Javier
Aguirreamalloa, and Luis Corres Avendaño: Market Risk Premium Used in 56
Countries in 2011: A Survey with 6,014 Answers; IESE Business School, Univ. of
Navarra, Spain , 25April 2011; SSRN <http://ssrn.com/abstract=1822182>.
[FernandezAA:12]
Pablo Fernandez, Javier Aguirreamalloa, and Luis Corres Avendaño: Market Risk
Premium Used in 82 Countries in 2012: A Survey with 7,192 Answers; IESE
Business School, Univ. of Navarra, Spain, 13 June 2012; SSRN
<http://ssrn.com/abstract=2084213>.
[FernandezAL:13]
Pablo Fernandez, Javier Aguirreamalloa,
and Pablo Linares:: Market Risk Premium and Risk Free Rate Used for 51
Countries in 2013: A Survey with 6,237 Anwers; IESE Business School, Univ. of
Navarra, Spain , 26 June 2013; SSRN
<http://ssrn.com/abstract=2286009>.
[FernandoSB:13]
Basso Leonardo Fernando, Herbert Kimura,
Juliana A. Saliba, and Erica S. Braune: “The Impact of Intangibles on Value
Creation: Comparative Analysis of the Gu&Lev Methodology for the United
States Software and Hardware Sector; Mackenzie University, São Paulo, Brazil,
5th European Conference on
Intelectual Capital, Bilbao, April 2013.
[FiferB:94]‡
Samuel Fifer and Lanning Bryer: “The Acquisition and Disposition of
Intellectual Property in Commercial Transactions, The U.S. Perspective”;
Chapter 8 in Melvin Simensky and Lanning Bryer (eds.): The new Role of Intellectual Property in Commercial Transactions;
Wiley 1994. Defines
a.o. Trade secrets.
[Fieldhouse:11] Andrew Fieldhouse: For Joint Select Committee, many good
Options; EPI, The Century Foundation, Issue Brief #316, 13 Oct.2011. Information on tax changes, as Capital gains 2012-20021
$168B, capital gains + dividend $760B 2012-2021. [OMB MSR:2012
[Fifield:11]
Anna Fifield: “Buffet calls for tax rises for the rich”; Financial Times, 15 Aug.2011.
[Finfacts:10] Finfacts
Ireland: US Multinationals Profit from Tax Havens; retrieved 2010, Finfacts Reports, http://www.finfacts.com/irelandeconomy/usmultinationalprofitsireland.htm>
[FinneganM:78]
Marcus B. Finnegan and Herbert H. Mintz: "Determination of a Reasonable
Royalty in Negotiating a License: Practical Pricing for Successful Technology
Transfer"; Licensing Law and Business Report 1 No.2 , June-July
1978, p.19. Cited
by [Contractor:81] . Not at SUL.
[FisherH:11] Ken Fisher and
Lara Hoffman: Markets Never Forget (But
People Do); Wiley, 2012.
[FisherS:09] William W. Fisher & Talha Syed: A Prize System
As A Partial Solution To The Health
Crisis In The Developing World ; Discussion Paper No.5 10/2009
Harvard Law School Cambridge, MA
02138. An
alternative to patent protection, but the government pays the prize for
success.
[Fishman:12]
Stephen Fishman:: Amortizing Patents. Copyrights and Other Intangible Property;
http://www.intellectualpropertylawfirms.com/resources/invention-law/amortizing-patents-copyrights.htm
, 2012.. Simplistic,
incomplete.
[FishmanW:01] Raymond Fishman and ShangYu Wei: Tax rates and Tax
Evasion: Evidence from `Missing Imports’ in China; National Bureau of Economic
Research (NBER), working paper 8551, Oct.2001.
[FlignorO:06] Paul Flignor and David Orozco: Intangible Asset & Intellectual
Property Valuation: A Mutidisciplinary Perspective; WIPO , Kellogg School of
Business, June 2006. Exclusive licenses.
[Folbre:11] Nancy Folbre: Tax Havens and Treasure Hunts; The New York Times , 4 April 2011. Shows Corporate
tax revenue/ GDP.
[Fornito:05] Roberto Fornito:
Haftung imVerein; Müller-Eckstein
Rechtsanwälte, Staad, Switzerland, 2005.
[Fors:97]‡
Gunnar Fors: “Utilization of R&D Results in the Home
and Foreign Plants of Multinationals”; The Journal of Industrial Economics, Vol.45 Issue 3,
pages 341–358, September 1997. R&D is used by
CFCs, but not the other way around.
[Foster:12]
Noel Foster: Africa, report 2012.
[Fowler:99]
Martin Fowler and Kent Beck: Refactoring: Improving the design of existing
code;14th edition, 1999,
[Fox:09] Justin Fox: The Myth of the Rational Market: A
History of Risk, Reward, and Delusion on Wall Street; Harper Business, 2009. On Kindle and hardcover.
[Foxman:12] Simone Foxman, 21
mar.2012: Citi’s Chief Econmist Rips the US Tax system For Almost Giving Him `a
Nervous Breakdown’” Business insifer, 21.Mar21012. Buiter:12] “Citigroup’s
chief economist Willem Buiter said on Bloomberg Radio Tuesday, fiscal policy
at the federal level we're talking about now is a complete disaster. “As a U.S. citizen, I had to try and get the
data together to give to the person who prepares my tax returns, and I almost
had a nervous breakdown collecting the data! The US tax system is
completely incomprehensible! My wife and I are both PhD’s in economics—both of
us!—and we can’t make head or tails of it.”’
[FPA:11]
Fiscal Policy Associates: Developing Consistent Tax bases for Broad-based
Reform ; Sep.2011. Also good summary data. Includes a national sales tax. Support for Herman
Cain 9-9-9 proposal. Run by Gary Robbins.
[Fram:12]
Alan Fram: Simpson-Bowles Plan rejected by the House; AP 29
mar 2012? 382-38.
[Frank:05]
Steven J. Frank: "Source Out, Risk In"; IEEE Spectrum, April
2005. pp.60,62. Outsourcing, Globalization risk.
[Frank:11] Robert Frank: Are Taxes Causing the Rich to Renounce
Their Citizenship?; The Wealth report, The
Wall Street Journal, 13 June 2011. 499 left in 1q2011. No indication if they are rich.
[FrankOW:09]
Peter B. Frank, Vincent E O'Brian, and Michael J. Wagner: "Patent
Infringement Damages"; Chapter 22
in Roman Weil, Michael J. Wagner, and Peter B. Frank: Litigation Services Handbook, 2009 cum. Supplement, Wiley.
[FreemanAB:09] Nick J. Freeman, George Abonyi, and Atipol Bhanich
Sipapol: Globalization of Production and the Competitiveness of
Small and Medium-sized Enterprises in Asia and the Pacific: Trends and
Prospects; United Nations Economic and Social Commission for
Asia and the Pacific, Studies in Trade
and Investment No.65 (ST/ESCAP/2540). 2009.
[Friedman:62]
Milton Friedman: Capitalism and Freedom, The Distribution of Income; University of Chicago Press, 1962. "All things considered, the personal income tax
structure that seems to me best is a flat-rate tax on income above an exemption,
with income defined very broadly and deductions allowed strictly for defined
expenses of earning income”; [p.174.] .
[Friedman:86]‡ Milton Friedman: On the 1986 Tax Reform;
Wall
Street Journal: 7 July 1986. The end result is
a tax system so complex that literally no one can master it in full detail.
--From the citizens' point of view, the function of tax legislation is to
decide who shall pay how much to finance government spending. But from
Congress's point of view, tax legislation has an additional and very important
function: It is a way to raise campaign funds.
Why is it that hardly a year passes without a new tax bill? The reason
is that so long as a tax bill is under consideration, with many billions of dollars
at stake, lobbyists are actively pressing for the introduction or retention of
special provisions to benefit their clients. And so long as lobbyists are
active, thousand-dollar-a-plate dinners and similar devices will tap them for
campaign funds. That is why members of Congress put such a high value on being
assigned to the Ways and Means or Finance committees. And that is also why
Congress has denied the citizenry the benefit of a <stable> tax system,
changed only at long intervals, to which individuals and enterprises could
adjust, rather than having to cope with continual and complex changes year
after year.
[FriedmanW:03]‡ Jack P. Friedman and Roman L. Weil
(eds): Litigation Support Report Writing: Accounting, Finance, and Economic
Issues; Wiley, 2003.
Chapter 9: Robert L. Vigil: Intellectual Property /Software.,
pp.172-198. Have copy of section.
[Frisch:89]‡ D. Frisch: “Method for Computing Royalty Under White Paper's BALRM”; Tax
Notes Today, 89 TNT 107-30, 19 May 1989.
[FrondelS:03]
Manuel Frondel and Christoph M. Schmidt,:
"Rejecting capital-skill complementarity at all costs“; Economics Letters, Elsevier, Vol.80 no.1, pp.15-21, July 2003; ZEW
Discussion Papers 01-27, ZEW -
Zentrum für Europäische Wirtschaftsforschung / Center for European Economic
Research.
[FuchsKP:97] Victor R. Fuchs, Alan B. Krueger,
and James M. Poterba: "Why do Economists
disagree About Policy?“; NBER Working Papers
no.6151,
National Bureau of Economic Research, Inc. 1997.
[Fukuyama:91]‡ Francis Fukuyama: The End of History and the Last Man;
Free press, 1991; reprint, 2006. At Johns Hopkins. Predicts integration and liberal democracy eventually
globally, and no stable communism . Theories that can be tested within 20
years?. Concepts from Hegel and Nietzsche influenced new geopolitical policies
from the US. In the light of those policies, his ideas are changing, in
public. See also Huntington.
[Fukuyama:07]‡ Francis Fukuyama: America at
the Crossroads: Democracy, Power, and the Neoconservative Legacy; 2007. Push back from [Fukuyama:91] .
Have.
[FulghumSB:12]
David Fulghum, Bill Sweetman, and Amy Butler: “China’s Role in JSF’s Spiral
Costs”; Aviation week, 2012. Foreign
contractors have coaused loss of protected IP.
[FullertonH:89]
, Don Fullerton and &, Yolanda Kodrzycki Henderson: "The Marginal Excess Burden of Different Capital Tax
Instruments“; The Review of Economics and Statistics, MIT
Press, Vol.71 no.3, pp.435-442, Aug. 1989;; NBER
Working Papers 2353, National Bureau
of Economic Research, Inc. [FurmanB:08]
Jason Furman and Jason Bordoff: Path
to Prosperity; Hamilton Project Ideas on Income Security, Education, and
Taxes, Brookings Institution Press, 2008.
[Gabriel:10] Caroline
Gabriel: 3G
Americas remaned for the 4G era; Retink Wireless, 28 Sep.2010.
[Gabriel:11] Trip
Gabriel:
“Gingrich Strikes Economic Themes in Hitting Romney”; New York Times, 27
Dec.2011. Supply
side invokes Arthur Laffer curve , Jude Wanniski
[GabrielS:11] Trip
Gabriel and
Susan
Saulny:
“With Just Three 9s, Cain Refigured
Math for Taxes”; New York Times, 12
Oct.2011. computed
by adviser, Rich Lowrie, for Hermann Cain, uses Laffer curve.
[Gaetan:06]
Nicodaeme Gaetan: "Corporate tax
competition and coordination in the European Union: What do we know? Where do
we stand?“; European Economy -
Economic Papers 250, Directorate
General Economic and Monetary Affairs, European Commission, 2006.
[Galandak:13]
John Glandak: Uncertainty: Good for Science, Bad for Bisiness; Commerece, The
Business of New Jersey, www.commercemagnj.com, Jun.2013. .. 23% of small business owners cite taxes as the
single most important problem [NFIB].. it costs small businesses 76% more
(basis?) yo comply with the tax code than larger competitors, 2 billion hours
or ~$18B annually, corporate only would increase taxes paid by individual owners of
pass-through usinesses by 8% or $27B annually. 77$% are organized as S-corps,
LLCs. LLPs, or Sole Proprietor ships.
[Gale:99]
William G. Gale: What can America Learn from the
British Tax System: in [Slemrod:99] . tax expenditures in the US 1993 $403B, stable laws.
The UK provides no tax relief on second homes. Ref to effect of changes in
capital gains.
[GaleH:10] William G. Gale and Benjamin H. Harris: A Value-Added Tax for the United States: Part of
the Solution; Economic Studies,
Brookings Institution, 22 July 2010. VAT
[GaleH:11]‡ William G. Gale and Benjamin H. Harris: Don’t Fall for Corporate Repatriation; Politico, Brookings Institution, 27 June
2011. 1.5Trillion
offshore. [ACM].
[Gale:11O]
William G. Gale: The Big Hidden Tax Ideas In Obama’s Budget; Brookings
Institution, 22 Sep.2011. Buffet Rule
instead of AMT. 28% limit to itemized deduction. Affects excessively high
mortgage deductions. No AMT and 30% tax rate for income above $1M, “raising
taxes is a better way to control spending -- making the cost of spending clear
and current”
[Galor:04] Oded
Galor: From Stagnation to Growth: Unified Growth Theory; Handbook of Economic Growth, Vol.1, 2004, pp.171-293 . <http://ideas.repec.org/h/eee/grochp/1-04.html> . Long history
[GalorM:02] Oded Galor and Omer Moav: ``Natural
Selection and The Origin of Economic Growth”; Quarterly Journal of Economics, Vol.117 no.4, 2002, pp.1133-1191.
[Galston:12] William
F. Galston: Reforming Institutions;
Brookings, 2012. Control tax
expenditures. Control aggregate. Ryan sunset amd limuiting proposals, Diverse
suggestions.
[Gannes:10] Liz Gannes: “Case studies in freemium: Pandora,
Dropbox, Evernote, Automattic and MailChimp”; gigaom,
26 Mar. 2010,
http://gigaom.com/2010/03/26/case-studies-in-freemium-pandora-dropbox-evernote-automattic-and-mailchimp/. from Sonny Chan CS207.
[GAO:85]
Tax Adminstration, the federal/state tax information exchange program; GAO
report to the Commissioner of Internal Revenue , December1985. Nothing specific, based on sample
[GOA:94] GAO, Tax Administration: Compliance Measures and
Audits of Large Corporations Need Improvement, GAO/GGD-94-70
.Washington, D.C.: Sept. 1, 1994,
[GAO:95]
GAO: International Taxation: Transfer
Pricing and Information on Nonpayment of Tax;
U.S. Government, GOA/GDD report 99-39, April 1995.
[GAO:96]
Government Accountability Office (GAO), GAO/GGD-96-109, Tax
Research, IRS Has Made Progress but Major Challenges Remain (June
1996).
[GAO:97] GAO Tax Administration: Factors Affecting Results
from Audits of Large Corporations,GAO/GGD-97-62, 17
Apr.1997.
[GAO:98] Tax
Administration: IRS Measures Could Provide a More Balanced Picture of Audit
Results and Costs, GAO/GGD-98-128 23 Jun.1998. 18IRS’s computer matching programs
obsolete
[GAO:03] GAO:
IRS and TIGTA Should Evaluate Their Processing of Employee Misconduct Under Section
1203; report GAO-03-394, February 14, 2003. Overdoing it leads to personnel problems.
[GAO:04] GAO, International Taxation: Tax Haven Companies were
More Likely to Have a Cost Advantage in Federal Contracting; U.S. General
Accounting Office report GAO-04-856, Jun.2004, 27pp.
[GAO:05] GAO:
Tax Compliance: Better Compliance Data and Long-term Goals Would Support a More Strategic IRS Approach to
Reducing the Tax Gap; Government Accountability
Office, report GAO-05-753, 12
Jul. 2005. Low
taxpayers of large corporations.
Chapter 9:
[GAO:05P] GAO: Tax
Policy: Summary of Estimates of the Costs of the Federal Tax System; GAO-05-878,
Aug. 2005. Cost
of Compliance
[GAO:07] GAO:
Tax Administration: Additional Time Needed to
Complete Offshore Tax Evasion Examinations; report GAO-07-237, March 2007.
[GAO:08] GAO:
Comparison of the Reported Tax Liabilities of Foreign- and U.S.-Controlled
Corporations, 1998-2005; report GAO-08-957,
July 2008.
[GAO:08F] GAO: Tax
Compliance: Businesses Owe Billions in Federal Payroll Taxes; GAO-08-617, 23 July 2008). uncollectible. gaO noted that the IRS
assigned to revenue officers about $7 billion, and about $9 billion remained in
the queue awaiting assignment.In addition, GAO’s analysis found that the number
of businesses with more than 20 quarters of tax debt (five years of unpaid
payroll tax debt) more
than doubled between 1998 and 2007
[63pp.Of the 100 largest
US corporations 83 have taxhaven subsidiaries.
[GAO:12] GAO: Internal Revenue Service, Interim Results of 2012 Tax
Filing Season and Summary of the Fiscal Year 2013 Budget Request; US 33pp. 2012 budget %305M less than 2011. Worse performance
due to other finding peiorities. Requested increase $944.5M (8%) + 2.5B + 330M
for modernization . Reduced performance
goals. Data in VIC spreadsheet.
[GAO:13] GAO: Corporate Income Tax,
Effective Tax rates an Differ Significantly from the Statutory Rate; US 38pp. 13%, of
world-wide, 17% with local taxes, 22.7 with unprofitable filers.
[GarciaUW:01]†
Hector Garcia-Molina, Jeffrey Ullman, and Jenifer Widom: Database Systems,
The Complete Book ; Prentice-Hall, 2001.
[GarciaZambranoRG:13] Lidia Garcia-Zambrano, Arturo
Rodriguez-Castellanos and Jose Domingo Garcia-Merino: Effect Of Investments On
Training And Advertising On The Market Value Relevance Of Intangibles; University
Of The Basque Country, Spain, 5th European Conference on Intelectual
Capital, Bilbao, April 2013.
[GardnerR:98]†
William Gardner and Joseph Rosenbaum: Intellectual Property: Database
Protection and Access to Information; Science,
Vol.281, Issue 5378, pp.786-787 , 7 Aug.1998.
[GarmusH:01]† David
Garmus and David Herron: Function Point Analysis: Measurement Practices for
Successful Software Projects; Addison-Wesley Information Technology Series,
2001.
[Garofalo:12] Pat Garofalo: CEOs of Tax Dodging Corporations Want to
Cut Their Own Taxes Too; Nation of Change, 15 May 2012. In Obama’s plan
for incomes over $250,000.
[Gates:98]‡
Bill Gates: "Compete, don't delete"; Economist, 11 June 1998.
[Gates:00]
Bill Gates: Business @ the Speed of Thought:
Succeeding in the Digital Economy; Warner books, 2000.
[Gates:04]
Bill Gates: "Losses due to copying must be balanced with disincentives and
costs of protection methods"; quote during a discussion on "Building
Confidence in a Connected Marketplace", 1 Oct 2004, Computer History
Museum, Mountain View, CA.
[GathmannS:07]
Christina Gathmann and Uta Schönberg: "How General Is Human Capital? A Task-Based Approach“; IZA
Discussion Papers 3067, Institute for
the Study of Labor (IZA), , 2007; Journal of Labor Economics, University of Chicago Press, Vol.28 no.1, pp.1-49, 2010.
[GaukeEa:10] David Gauke et al.:
Corporate Tax Reform: delivering a more comprehensive System; HM Revenue and
Customs, 20 Oct. 2010. Planning By
moving to full deductabilty of dividends for corporate profits, territorial
taxation becomes closer. But taxhavens can stll be addressed.
[Gauzente:02] Claire Gauzente: “Ethical marketing for competitive
advantage on the Internet”; Academy of Marketing Science Review,
vol.2001 no.10, 2002, http://www.amsreview.org/articles/gauzente10-2001.pdf.
from Sonny Chan CS207.
[Gay:02]
Joshua Gay: Free Software, Free Society,
selected essays of Richard M. Stallman; GNU Press, 2002; reprinted with a
foreword by Lawrence Lessig, 2009. Does not try to
deal with software in general, but focuses on compilers, editors, and opeationg
systems, while implying more [ACM].
[Garst:11]
Huntsman Plan Targets Double Taxation. Posted by Brian Garst on Aug.31, 2011; Eliminate The
Taxes On Capital Gains And Dividends In Order To Eliminate The Double Taxation
On Investment. Capital gains and dividend taxes amount to a
double-taxation on individuals who choose to invest. Because dollars invested
had to first be earned, they have already been subject to the income tax.
Taxing these same dollars again when capital gains are realized serves to deter
productive and much-needed investment in our economy.
[George:08]
J. Russell George: Treasury Inspector General for Tax Administration Seminanual
Report to Congress, Oct.2001 –March 2008; Inspector General for Tax
Administration, TIGTA, 2008. Focus on intermnal audits. Acount Managment Servives (AMS).
Tax gap of self-emplyment tax is $39B! Security. Tax law complexity. Excess IRA
contributions. Idnty theft causing misreporting of income.
[George:11] J.
Russell George: Management and Performance Challenges Facing the Internal
Revenue Service for Fiscal 2012; Inspector General for Tax Administration,
TIGTA, 14 Oct.2011. Tax l;aw changes, specically from the affordable Health care Act (HHS),
includes tax credits. Earned Income Tax Credit EITC payment, Additional Child
Tax Credit, Hope Scholarship cridt (dep.education) , Refundable adption
credits, Electric vehicle credit (transporation) ,Hombuyer credit, Globalization Holdings have grown from $188B
to in 1976 to 14.5T in 2007. Lack of information. Dealing with differing jurisdictions.
Focus on-highrisk cases. FATCA,
Significant foreign opposition to FATCA. Solution is to withhold 30% of
apyments to forieign finacoal institution
- but does not address IP. .. Effort needed to implement changes. Hunman
capital “attempts by taxpayers and tax practitioners to evade compliance with
the tax laws become more sophisticated.” Globalization US businesses from 368B
(1996)to nearly 15T (2007) “The IRS is still challenged by a lack of
information reporting on many cross-border transactions. In addition, the varying legal requirements
imposed by different jurisdictions result in complex business structures that
make it difficult to determine the full scope and effect of cross-border
transactions.”, “The IRS expects that these efforts will improve international
tax compliance by allowing it to focus on high-risk issues and cases with
greater consistency and efficiency.”, “Taxpayers with undisclosed foreign
accounts and assets who do not submit a voluntary disclosure run the risk of
detection by the IRS. If caught, these
taxpayers face the imposition of substantial penalties, including the fraud and
foreign information return penalties, as well as an increased risk of criminal
prosecution. “, “According to the IRS
Commissioner, “FATCA is an important development in U.S. efforts to combat
offshore noncompliance. At the same
time, the IRS recognizes that implementing FATCA is a major undertaking for
financial institutions.”[1][32]
Based on the initial feedback from foreign financial institutions as well as
foreign governments, the IRS will continue to face significant opposition from
abroad in implementation of this Act.”
[GerdesS:09]‡
Lindsey Gerdes and Louis Lavelle: “Best Places to Launch a Career”; Business Week, 14 Sep.2009.
[GerthMH:11] Jeff Gerth, Megan Murphy, and Vanessa Houlder:
Corporations Couldn’t Wait to `Check the Box’ on Huge Tax Break; Probublica, Nation of Change, 27 Sept.2011.
[
Gideon:05] Kenneth W. Gideon: The Comprehensive Business Income Tax; presentation slides, Skadden, Arps, Slade, Megher and Flom, 13 May 2005, <govinfo.library.unt.edu/taxreformpanel/meetings/.../gideon_052005.ppt>. Distortion due to interst deduction and LLCs.
[Gigerenzer:08] Gerd Gigerenzer: Gut Feelings: The Intelligence of the Unconscious; Penguin 2008. Behavioral economics is often used as a club to declare that people are irrational. But many forms of allegedly rational behavior are actually efficient. Real people are better at cooperating than Homo economicus.
Gigot:12] Paul Gigot?: Obama’s
Dividend Assault; WSJ editorial, 22 Feb.2012. Diatribe.bad arithmetic at 20% actual
the shareholder receives 80%, and at 39.6% pays a total 48.3% + 3.8healthcare
=52%, much but not 64% now 32% Increase
is x 1.63, much, but not 3 x as claimed . Interesting graph.
[Gilb:05]†
Tom Gilb: Competitive Engineering;
Elsevier, 2005.
[ To be engaged in opposing wrong affords but
a slender guarantee of being right.
[Gladwell:07] Malcom Gladwell: Open Secrets; The New Yorker Magazine, 8 Jan.2007; also in What
the Dog Saw; Little Brown and Company, 2009.
[Gladwell:11] Malcom Gladwell: The Creation Myth; The New Yorker
Magazine; 16 May 2011. Xerox, Parc, Apple, and the truth about innovation. [Box]
[Glass:98]†
Robert L. Glass: In the Beginning: Recollections of Software Pioneers;
IEEE Press, 1998.
[Glass:98] <change to
03 >Robert L. Glass: "Maintenance: Less is not more"; IEEE
Software, Vol.15 No.4, July/Aug.1998
[Glass:03] Robert L. Glass: Facts and Fallacies of Software
Engineering; Addison Wesley, 2003.
[Glass:12]‡
Robert L. Glass: “A Study About Software Maintenance”; IS Management Vol.29 no.4, 2012, pp 338-339.
[Glass:11V]
Robert L. Glass
and Iris Vessey:
“Naïveté Squared: In Search of Two Taxonomies and a Mapping between Them”; IEEE Software, Vol.28 no.5, 2011, pp:14-15.
[Gleckman:02] Howard Gleckman: Sealing off the Bermuda Triangle?; Business Week, 1 July 2002. Corporate Tax
Shelters Includes example of Inversion by Tyco , using ADT, and transfer pricing. Chap 10.
[Gleckman:02C]‡
Howard Gleckman: Flatten the Corporate Tax Code; Business Week, 26 Feb.2002.
[Gleckman:10]
Howard Gleckman: The Bowles-Simpson Plan: Tax Hike Or A Tax cut; Forbes, 11 Nov.2010.
[Gleckman:11] Howard Gleckman: Gingrich’s
Tax Plan: Big Tax Cuts, Big Deficits; Tax Policy Center and Brookings
Institution, 12 Dec 2011.
[Gleckman:12]
Howard Gleckman: Rick Santorum's Tax Plan Would Blow A Huge Hole In The
Budget; Forbes, 3 July 2012.
[Gleeson:94] William Gleeson: Anderson near to Pounds 1m per
partner; The Independent, 12 June
1994. In
five of the big six firms, the average profit per partner ranges from between
pounds 340,000 and pounds 418,000
[ShapiroV:99] Carl Shapiro
and Hal R. Varian: Information Rules: a Strategic Guide to the Network Economy;
Harvard Business Press 1999. Metcalfe’s law on
the quadratic value of networks relative to size. .p.184 credited to Goerge
Glider, 1993. But see [BriscoeOT:06].
[Gobeli MK:01] D. H.
Gobeli, C. S. Mishra, and H. F. Koenig:: “Strategic value of technology and
brand equity for multinational firms”; in [Contractor:01] pp.321–333.
[Gobry;11]
Pascal-Emmanuel Gobry: “Boom! CityVille zooms past 100 million users”; Business
Insider, 13 Jan. 2011, http://www.businessinsider.com/boom-cityville-zooms-past-100-million-users-2011-1.
Freemium,
from Sonny Chan CS207.
[GolderY:04]
Peter N. Golder and Gerard J. Tellis: Growing, Growing, Gone: Cascades,
Diffusion, and Turning Points in the Product Life Cycle; International
Journal of Research in Marketing, 2004 - Elsevier .
[Goldman:97]
Eric Goldman: Private label and Co-Branding Deals: New Deal-Making Paradigms on
the Internet; Journal of Online law,
1997.
[GoldscheiderJM:02] Robert Goldscheider, John Jarosz, and Carla Mullhern: "Use of the
Twenty-Five Percent Rule in Valuing Intellectual Property"; Les Novelles, LES, Dec.2002. See Chapter 3 in [Parr:07] . Based on a 1950 study of a Swiss subsidiary of a U.S.
company. Three year renewable terms, 20% profit, 5% royalty on revenues. IP was
being maintained. Mentions that [Lee:92] , among many others, cites that rule. ] . Fig 3 vs 6 shows general unreliability of royalties based on profit, as [Parr:07 warns]
. It appears that the summaries do not
consider that many semiconductor products require multiple licenses. 0%
licenses are likely for association members.
[Gooch:00] Lawrence Gooch: "In-Process R&D";
Chapter 9, p.176, Handbook of Advanced Business Valuation, McGraw-Hill, 2000. "... the cost
approach is generally not a good measure of IPRG 9in-process R&D) value”;
<Chap .5>
[Goodfriend:93]‡
Marvin Goodfriend: Eurodollars; Chapter 5 in <> ; Federal reserve Bank of
Richmond, VA, 1993 . 1988 estimate by Morgan 2,587B
[GoodlatteS:11] Bob Goodlatte and Rober C.
Scott: Business Activity Tax Simplification Act, (BATSA); HR 1439, 13 April
2011. State and Internet
taxation harmonization. Cites case of Quill Corp. vs North Dakota.
[Goodman:67]‡ George J.W. Goodman (George (Adam
Smith): The Money Game; Random House, 1967,
republished 1976. On the stock market: “in the long-run the
future earnings represent present value [although] in the short run the
dominant factor is the elusive [...] temper of the crowd. also George J.W
George." The world is not the way they tell you it is”.
[Goodman:82]‡ George J.W. George (Adam Smith): Paper Money; MacDonald & Co., 1982.
[Goolsbee:00]
Austan Goolsbee: “In a World Without Borders: The Impact of Taxes on Internet
Commerce”; Quarterly
Journal of Economics 115, May 2000,
561-576.> Globalization.
[Goolsbee:04]‡
Austan Goolsbee, University of Chicago - Graduate School of Business; National
Bureau of Economic Research (NBER): “The Impact of Corporate Income Tax:
Evidence from State Organizational Form”; Journal
of Public Economics, Vol.88 no.112004, pp.2283-2299. In Retail
establishments a 1% increase in corporate tax vs non-corporate tax reduced the
share of corporate forms by 2.5% and 7% of sales.
[GoolsbeeC:02]
Austan Goolsbee and Judith A. Chevalier: Measuring Prices and Price
Competition Online: Amazon and Barnes and Noble; July 2002, University of Chicago - Graduate School of
Business; National Bureau of Economic Research (NBER), NBER Working Paper No.W9085. First-mover advantage,
price leverage 20%. RB and QX case.
[GopalMKS:03]
A.Gopal, T. Mukhopadhyay, M.S. Krishnan and K. Sivaramakrishnan: “Contracts in
Offshore Software Development: An Empirical Analysis”; Management
Science, Vol.49 no.12, 2003. pp.1671-1683.
[GoreR:98] Al Gore and Robert E. Rubin: Reinventing Service at
the IRS; GPO report 1998. MS01, Eliminate dollar goals.
[Gordon:82]†
Myron Gordon: The Investment, Financing, and Valuation of the Corporation;
The Irwin Series in Economics, Greenwood Press reprint, 1982.
[Gordon:86]‡
Roger H. Gordon: “Taxation of Investment and Saving in the World Economy”; American
Economic Review, Vol.76, 1986,
pp.1086-1102.
[GordonG:97] Joseph R. Gordon and Myron J. Gordon: "Finite
Horizon Expected Growth Model"; Financial Analysts Journal, Vol.53
no.3, May June 1997, pp.52-61.
[GordonH:02] Roger H. Gordon and James R. Hines jr.: “International
taxation”; in [AuerbachF:02] pp.1395-1995.
[GordonL:00]‡ Roger H. Gordon
and Young Lee: Do Taxes Affect Corporate Debt Policy? Evidence from U.S.
Corporate Tax Return Data; Korea Development Institute, 25 Aug 2000.
[GordonM:95]‡
Roger H. Gordon and Jeffrey K. Mackie-Mason: “Why is there corporate
taxation in a small open economy? The role of transfer pricing and income
shifting”; in Martin Feldstein, James R. Hines Jr. and R. Glenn Hubbard eds., The effects of taxation on multinational
corporations (Chicago: University of Chicago Press, 1995). A 10% reduction in
non-corporate income tax only shifted 0.2% of assets out of corporation
form.[deMooij:07]‡ risk is more important. , but see [Goolsbee:04]‡
<Chap.9>
[GordonN:97]‡
Roger H. Gordon and Soren Bo Nielsen, Tax evasion in an open economy:
Value-added vs. income taxation; Journal
of Public Economics, Nov.1997, 66 (2), 173-197.
[GordonS:00]‡ Roger H. Gordon
and J. Slemrod: “Are ‘Real’ Responses to Taxes Simply Income Shifting Between
Corporate and Personal Tax Bases?”
in J. Slemrod, ed., Does Atlas Shrug? The
Economic Consequences of Taxing the Rich; Russell Sage Foundation and Harvard
University Press, 2000., 240–80.
[Gowri:98] Aditi Gowri: “Speech and Spending: Corporate Political
Speech Rights Under the First Amendments”; Journal of Business Ethics, Vol.17
no.16, Dec.1998, pp.1835-1860.
[GPO:12] US budget Summary Tables, Government Printing Office,
2009. [Not cited]
[Graetz:02]
Adjust personal income taxes to compensate for uneven
burden of expenditure taxes.
[Graham:1994]†
Dorothy Graham: "Testing"; in [Marciniak:94]
[
[Gravelle:09]‡ Jane G. Gravelle: Tax Havens:
International tax avoidance and evasion; Congressional research Service, 9 July
2009. . [Not cited]
[GravelleS:01] Jane Gravelle and Kent A. Smetters: ‘‘Who bears the Burden of the Corporate Tax
in the Open Econmy?’’; NBER working
paper no.8280, May 2001. Basis for [GravelleS:06] . Employee benefit assignments.
[GravelleS:06] Jane Gravelle and Kent A.
Smetters: ‘‘Does the Open Economy
Assumption Really Mean That Labor Bears the Burden of a Capital Income Tax?’’; Advances in Economic Analysis & Policy,
Vol.6 no.1, 2006. Counteracts employee benefit assignments.
[Gravelle:13]
Jennifer Gravelle: Options for Taxing U.S. Multinational Corporations;
Congressional Budget Office, Congress of the United States, report, revised 13
Feb 2013. Reviewed by Kimberly Clausing
anbd Dsavid Shay.
[Greeley:12] Brendan Greeley: ”Obama
Spoils for an Election Year Tax Fight”; Bloomberg
Businessweek, 27 Feb.2012. Pp.34-36. 28%rate. 2.7% of tax take on 2010. Keeps R&E,
domestic manufacturing, & renewable energy.
[Green:12] Petr S.
Green: “Plenty of Love, But where is
the Acxtion?; Bloomberg Businessweek,
17 Sep.2012.
[Greenstein:11] Robert Greenstein: Gang of Six Plan
Represents Useful Step Forward, Despite Troubling Elements; Center on Budget
and Priorities, 22 July 2011. Basically Bowles-Simpson.
[Greenstein:12]
Robert Greenstein: Cooper-LaTourette Budget Significantly to the Right of
Simpson Bowles Plan; Center on Budget and Priorities, 28 March 2012. Adaptation of
Bowles-Simpson.
[Gregory:12]
Dolores W. Gregory: IRS Withdrawing 2007 Issue Paper on Cost
Sharing Buy-Ins; BNA Daily Tax Report,
Jan.20, 2012.
[Gregory:12T]‡
Dolores W. Gregory: “Transfer Pricing: IRS, Treasury Officials Field Questions
Related to new Cost Sharing Regulations”; BNA
Daily Tax Report, 15 March 2012. Recomputing RABs. Go back to basic principles if in
doubt
[Gregory:13] Dolores W. Gregory: Transfer Pricing: Maruca Says IRS litigatiom
emphasizing Reasonable Outcomes; BNA
Daily Tax Report, June 7, 2013. Focus on income-based methods.
[GregoryS:11] Neil
Gregory and Susan Symons: Paying Taxes 2011, The global picture; The Word Bank Group and Price Waterhouse
Coopers, PWC, 2011.
Compares 183 countries. Taxes are on the average nearly half
of earnings. Worlswide taxes are down 5% between 2006-2011.
[GriffithK:04] Rachel Griffith and Alexander Klemm: "What has been the tax competition experience
of the past 20 years?“; Institute for
Fiscal Studies, IFS working paper W04/05, 2004.
[GriffithMO:11]
Rachel Griffith, Helen Miller and Martin O'Connell: "Corporate taxes and
the location of intellectual property,"
CEPR Discussion
Papers 8424, 2011. C.E.P.R.
Discussion Papers.
[GriffithS:09] Cara
Griffith and Stephanie Stewart: Drop shipments and flash title: establishing sales tax
nexus in complex commercial transactions; The
Tax Adiser, Vol.40 No.9 American Institute of CPAs, 22 Sep.2009. On Amazon bookshelf. Defines, but applies it to State taxes.
More description in [Waters:09]‡.
[GriffithsT:93]†
Thomas Griffiths and Joshua Tenenebaum: Teacakes, Trains, Taxicabs, and Toxins:
A Bayesian Account of Predicting the Future; Stanford Business School report,
1993.
Grilliches:67]
Zvi Grilliches: paper on measuring current effects and future effects of
IGE.
[Grilliches:84]
Zvi Grilliches: R&D, Patents, and Productivity; Univ. of Chicago
Press, 1984.
[Grimes:11] Seamus Grimes: Can China become an Innovation Hub?;
East Asian Bureau of Economic Research, <http://www.eastasiaforum.org/2011/07/22/can-china-become-an-innovation-hub/>,
2011.
[Grimes:13] Seamus Grimes: Slowly,
cautiously come the innovators; China
Daily, European Weekly, 12 Jul.2013.
[GrimesC:09] Seamus
Grimes and Patrick Collins: “The Contribution of the Overseas ICT sector to
expanding R&D investment in Ireland”; Irish
Geography, Routledge, Vol.42 no.1, pp.45-67, 1 March 2009. Increasing FDI
from manufacturing to R&D . Exploit local knowledge. Annual spending in US
$200B; Ireland euro 3.2B/ 5years (see WW.data) Low corporate tax rate
discourages R&D investment.
Nick
Grimmer and Stefan M.
Meisner: A First For FRAND: Federal Court In "Microsoft v.
Motorola" Sets FRAND Royalty Rates For Standard Essential Patents; Mondaq,
McDermott, Will, & Emery, 14 May 2013.
A reasonable rate for a
contributory patent set.
Esteban Rossi-Hansberg: "Trading Tasks: A Simple
Theory of Offshoring“; American Economic Review, American Economic Association, Vol.98 no.5 , Dec.
2008, pp.1978-1997..
[GrubertN:91] Harry Grubert and John Mutti: “Taxes, Tariffs and Transfer Pricing in Multinational Corporate Decision Making”; Review of Economics and Statistics, MIT press, 1991, Vol.73, pp.285-293. Uses 1982 data.
GrubertA:08] Harry Grubert and Rosanne Altshuler: “Corporate Taxes in the World Economy: Reforming the Taxation of Cross-Border Income”; in [DiamondZ:08]‡, pp.319-354.
Gu:01] Ferdinand A. Gu: Free cash flow, debt-monitoring and
managers' LIFO/FIFO policy choice; Journal of
Corporate Finance,Vol.7, Issue 4, Dec.2001, pp.475–492.
[GuellecP:03]
Dominique Guellec & Bruno Van Pottelsberghe De La Potterie, 2003. "The impact of public R&D expenditure on business
R&D“; Economics of Innovation and New
Technology, Taylor and Francis
Journals, Vol.12(3), pp.225-243. Other versions:
Bruno Van Pottelsberghe & Dominique Guellec, 2003. "The
impact of public R&D expenditure on business R&D“;
ULB
Institutional Repository 2013/6213, ULB -- Universite Libre de
Bruxelles; Dominique Guellec & Bruno van Pottelsberghe de la Potterie,
2000. "The
Impact of Public R&D Expenditure on Business R&D“;
OECD
Science, Technology and Industry Working Papers
2000/4, OECD Publishing.
GuL:11]‡ Feng Gu and Baruch Lev: “Overpriced Shares, Ill-Advised Acquisitions and Goodwill Impairment”; The Accounting Review, Nov.2011, Vol.86 no.6, pp.1995-2022. <chap 5>
[Günther:98]†
Oliver Günther: Environmental Information Systems; Springer Verlag,
Heidelberg, 1998.
[Gupta:91]† Sunil Gupta: Stochastic Models of
Interpurchase Time with Time-dependent Co-variates; Journal of Marketing
Research, Feb, 1991, Vol.XXVIII, pages 1-15. (Erlang Distributions)
[GuptEa:04]† Amar Gupta et
al. : Productivity from Information Technology (PROFIT) Initiative; working
papers on IT productivity and outsourcing, see http://mitsloan.mit.edu/research/profit/profit.html, 2004
GuptaS:07] Amar Gupta and Satwik Seshasai:
GuptaWS:09] Amar
Gupta, Gio Wiederhold , David Branson
Smith, and Devin Sreecharana : Outsourcing from the Perspectives of
International Protocols, Law, Intellectual Property, and Taxation; Arizona Legal Studies Discussion Paper 09-18 , University
of Arizona, 7 Jan. 2009, <http://ssrn.com/abstract=1324242>.
http://www.gurufocus.com/stock-market-valuations.php
[Guttman:03]‡ George
Guttman: “IRS Oversight Board’s Annual Report Too General to Be Useful”; Tax
Notes, Aug. 11, 2003, p. 755.
[Gwartney:05] James D.
Gwartney: Economic Fereedom of the World,
2005; The Cato Institute, 2005. Ratings by country.
[H&W:49]‡ "The intangibles being not reducible to
statistics, the food of all bureaucracy, count for nothing"; Here And Now, 30 Oct 1949.
[Haass:13] Richard Haass: Foreign Policy Begins at Home; Basic Books, 2013. Cannot separate domestic and foreoign plocy in
modern economics. Coeps are as big as middle-sized countries. have.
[HackerL12] Jacob S. Hacker and Nate
Loewentheil: Prosperity Economics,
Building an Economy for all; Yale
University, 2012. Myths. Worker productivity vs
compensation. Effective tax ratw low (p.59), Deferral . Low receipts. Stock
option graph p.63
[HackerP:10] Jacob S. Hacker and Paul Pierson: Winner-Take-All Politics: How Washington Made the Rich Richer--and
Turned Its Back on the Middle Class; Simon and Schuster, 2010. Entertaining
diatribe, blames politics, uninformed electorate. Have.
[Haldane:09] Andrew G. Haldane: Rethinking The
Financial Network; Executive Director, Financial Stability, Bank of England,
Speech delivered at the Financial Student Association, Amsterdam, April 2009, <http://www.bankofengland.co.uk/publications/speeches/2009/speech386.pdfl>. Importance of Information. If there is a
unifying them, it is informational failure. Cited by Shaxon
[Hall:93]‡ Bronwyn H. Hall: “The Stock Market's
Valuation of R&D Investment During the 1980's”; The American Economic
Review, Vol.83 no.2, Papers and Proceedings of the 105th Annual Meeting of the
American Economic Association, May 1993, pp.259-264. The relative life of advertising versus R&D. Hall (1993)
argues that advertising and R&D expenditures are roughly the same but that
the market valuation generated by R&D is four to five times the market
valuation generated by advertising. <Gio: because the life is longer.>
[Hall:99]‡
Robert E. Hall: "The Stock Market and Capital Accumulation"; NBER
Working Paper 7180, National Bureau of Economic Research, Cambridge MA, June
1999.
[Hall:01]‡
Bronwyn H. Hall: Tax Incentives for innovation in the United States; Asesoria
Industrial ZABALA-Spain, report Inno-00-93 the EU, 15 Jan.2001. R&E data and
many more.
[Haller:09]‡ Tobias Stanislas Haller, BSG: Saint
Matthew the Accountant Tenders His Account,
5" x 7" (oil) Tobias Stanislas Haller, BSG (brothers of Saint
Gregory) 2009. http://forallsaints.wordpress.com/2011/09/21/saint-matthew-apostle-and-evangelist/ Matthew appears in the Gospels as a tax collector for the
Roman government in the city of Capernaum.
[HallS:99] Joshua Hall and Jim Saxton: Tax Expenditures, A review
and Analysis; Joint Economic Committee, United States Congress, Aug.1999. Stanley S. Surrey helped institute the "tax
expenditure budget" in 1967 while he was Assistant Secretary for Tax
Policy in the Treasury Department. In 1972, the Joint Committee on Taxation
(JCT) began preparing an annual tax expenditure budget for the Committee on
Ways and Means. In 1974, the Congressional Budget and Impoundment Control Act
(PL 93-344) required that a list of tax expenditures be included in the annual
budget.
[HallR:07] Robert
E. Hall and Alvin Rabushka: The Flat Tax, silver anniversary edition; Hoover
Institution Press Publication 423, Stanford, 2007. Ignores taxhavens. Proposes elimination of taxes dividend and capital gains, but
includes interest earned by corporations. $127B not collected
-18%.500,000people involved. Cost $335B. Intel example on page 66. Data on dividends
and capital gains? Tax prepration time p.12; audir p.82,91 [xls/taxproposals]
[Halperin:10] Daniel Halperin; “Mitigating the Potential Inequity of Reducing Corporate Rates”; 1Tax
[Halperin:11] Daniel Halperin: "Is Income Tax Exemption for
Charities a Subsidy?"; Tax law Review, Vol.64 no.3 , Spring
2011,p.283-312.
[Hampton:96] Mark Hampton: The offshore interface: tax havens in the
global economy; Macmillan, 1996. Have. Includes Jersey study.
[
.Network effect. In the year 2000 $61.4B was spent for
prepackaged software, and $57B custom software. About $128B was spent by
companies for internal software development and maintenance [Bureau of Economic
Analysis] Chap. 12 provides data for routine and non-routine returns have.
[HanlonM:09] Michelle Hanlon and Edward L. Maydew: Book-Tax Conformity; National Tax
Journal, Vol.62, p.127, 2009. University of
Michigan and North Carolina , August 2006. Draft 2006
2010 National Tax Association meeting, EIASM 2011 Workshop on Current Research on Taxation at the University of Münster,
[Hansen:98] Reginald Hansen: Assessing
and Tax Accounting Principles in the German Civil and Commercial Code and the
Impact on Tax Compliance; European Journal of Law and Economics, Kluwer Academic Publishers, 1998, Vol.7
no.1, pp.15-47. Deterioration
of the Massgeblichkeitsprinzip by the folk in the City of London.
[Hanson:11]
Jay Hanson: From Capitalism To Democracy; Dieoff blog
<http://www.dieoff.com/
[Harberger:62]‡ Arnold V. Harberger:
The Incidence of the Corporate Income Tax; The
Journal of Political Economy, Vol.70 no.3, June 1962, pp.215-240. Equilibrium
effects modeled as Corp/noncorp x
labor/capital. Considers agriculture, real estate, and repair services non-corp
vs all others. Old model, later
improved. Shareholders bear the tax burden, not workers.
[Harberger:95] Arnold V. Harberger:
“The ABC’s of Corporation Tax Incidence, Insights into the Open-Economy Case”; Tax Policy and Economic Growth , Vol.51, 1995, p 51-73
[Harberger:08] Arnold V. Harberger:
“Corporate Tax Incidence, Reflections on What is Known, Unknown, and
Unknowable”; in [DiamondZ:08] ,
p.297-299.
[Hardy:03]‡ David R. Hardy: Assignment of Corporate Opportunities
-- The Migration of Intangibles; Tax
Notes, 145-33, July 28, 2003, p. 527.
Author
is with McDermott, Will & Emery. Globalization.
{Hargreaves:11]‡ Steve Hargreaves: “Big Oil’s 4$
billion tax break is in doubt”; CNNMoney,
29 April 2011.
[Harlan:1886] John Marshall Harlan: Santa Clara
County v. Southern Pacific Railroad; US Supreme Court, Session 228, 394, 1886. Corporate person
hood
[Harlon:66]
Willard Harlon: Essentials of the Stock
market; Vantage Press, 1966. Definitions, Back to Stanford.
[HaroffSV:97]
Dietmar Harhoff. Frederic M. Scherer, and Katrin Vopel, 1997. "Exploring the Tail of Patented Invention Value
Distributions“; CIG
Working Papers FS IV 97-27,
Wissenschaftszentrum Berlin (WZB), Research Unit: Competition and Innovation
(CIG); also Scherer, Frederic M. &
Harhoff, Dietmar & Vopel, Katrin, 1997. "Exploring the Tail of Patented Invention Value Distributions“; ZEW
Discussion Papers 97-30, ZEW -
Zentrum für Europäische Wirtschaftsforschung / Center for European Economic
Research. Patent office fees for non-exclusive
licensing are reduced by 50%. based on a syrvey 21 years after issuance,
[HarperM:13]
Christie Harper and Michael J. Moore: At Banks, the Balance shifts to
Shareholders; BBW, 7 Jan 2013. Balancing costs in
public companies, lowering compensation and reducing jobs. Pareto
balancing?
[Harrison:03] Bonnie Harrison: “Intangible Assets”; Chapter 10 in
Weygandt, Kieso and Warfield: Fundamentals
of Intermediate Accounting, Wiley 2003.
Intangibles
are written off over their useful lives, where the assets have determinable
useful lives. Where the intangibles have indefinite useful lives, they are not
amortized. Trademarks and Trade names are renewable indefinitely by the original user in periods
of 10 years each. Goodwill has an indefinite life and should not be amortized.
Impairment test performed at least annually, If applicable, loss recorded. No
impairment if sum of expected future net cash flows from use and disposal of
asset is equal to or more than the carrying amount
[HarsenC:11] Brett Harsen and
Alex Cwirko-Godychi: Equity and Executive Compensation at Recently Public
Companies in the Technology and Life Sciences Sector; Radford Research. 2011. Data on Pre-IPO
pay and derived early market value.
[
[Harvey:11]
J. Richard Harvey: “Offshore Accounts: Insider’s summary of FATCA and Its
Potential Future; Villanova Law Review, Vol.57 no.3, Dec. 2011”; Villanova
Public Law and Legal Theory Working paper series, No.2011-24, Dec. 2011. Success of FATCA
depends on other countries cooperating. Focus on Finacial institutions. Recommendations: Fix 1 Incomplete reporting
depends on due diligence, 2 passthru, requires multilateral coppration. Now
it’s unilateral.
[Harvey:12] J. Richard Harvey: FATCA and Schedule UTP, Are these
unilateral US actions doomed unless adopted by other countries?; Villanova
Public Law and legal Theory Working paper series, No.2012-2005, Mar.2012. FATCA requires
multilateral coppration. UYTP
disclousure Now it’s unilateral
[HassettB:07] Kevin
A. Hassett and Alex Brill: “Revenue-Maximizing Corporate Income Taxes: The Laffer
Curve in OECD Countries”; AEI Working Paper 137, Washington, DC, July 31, 2007,
www.aei.org/paper/26577. NNN
[HassettM:10] Kevin A. Hassett and Aparna Mathur: Spatial Tax
Competition and Domestic Wages; American Enterprise Institute for Policy
Research (AEI), Working paper, 1 Dec 2010. Update of a 2006 paper Taxes and Wages.
If capital stocks are depleted investment shifts to lower wage countries,
depressing wages
[HassettM:11] Kevin
A. Hassett and Aparna Mathur: Report Card on Effective Corporate Tax rates: United
States Gets an F; Tax Policy Outlook
2011,No.1, American Enterprise Institute
for Policy Research (AEI) no.1 Feb.2011. Statuary tax rates versus actual distribution.
[HauflerS:00]
Andreas Haufler and Guttorm Schjelderup: “Corporate Tax Systems and Cross
Country Profit Shifting”; Oxford Economic Papers, vol.2, 2000,
pp.306-325. Chap.9
[Hawkes:08] Alex Hawkes: Isle of Man urged to rebrand; Accountancy Age, 18 Jun 2008, <http://www.accountancyage.com/aa/news/1747208/isle-man-urged-rebrand >.
[Hawkins:99]
George B. Hawkins: "The Excess Earnings method – Should it be put out to
Pasture in Equitable Distribution cases?; Fair
Value, Bannister Financial Inc., Summer2009,
<http://www.businessvalue.com/valarticles_assets/Excess Earnings Time to
Go.pdfl>.
Have
on Kindle.
[Heath:09]
Joseph Heath: Filthy Lucre: Economics for People Who Hate Capitalism; Harpercollins Canada; 2009. Less of a diatribe
than the title implies. "Economic illiteracy on the left leads people of
good will to waste countless hour promulgating or agitating for schemes and
policies that have no reasonable chance of success or that are unlikely to
actually help their intended beneficiaries.''
[HedemannSP:10] Janice M. Hedemann, Michael Sebastiani. and Andre
Palmer: Calendar Year Tax Return Projections for the United States and IRS
Campuses, CY2010-2017; IRS Office of Research, Document 6186, Oct.2010. Returns:235,776K
total, 141,361K indiv, 24,967K est, /4 indiv businesses , 3597 partnership,
6756 corpor. 36M form 1042 foreign persons. 29,497K employment [xls/irs]
[HeiresG:04]
Neal Heiress and Jared Guckenberger: Process for calculating the economic value
created by a business activity; US Patent 20040267599 A1, issued 26 Jun 2004;
also US 744307. Many flow charts.
[Helleiner:94] Eric Helleiner: States
and the Reemergence of Global Finance; Cornell University Press, 1994. Tax rates are
going down except for oil companies. Eliminating tax deferrals will increase
corporate payments & taxes.
[Heller:08]
Michael Heller: The Gridlock Economy: How Too Much Ownership Wrecks Markets,
Stops Innovation, and Costs Lives; Basic Books, 2008 [have on Kindle]
[Helman:10] Christopher Helman: “What the Top U.S. Companies Pay
in Taxes”; Forbes Magazine, 1 April 2010.
[Helman:12] Christopher Helman: “Which Vompanies
pay the Most in Taxes”; Forbes,
16 Apr.2012. List of 25 companies, and their effectyive tax rate based on total
revenues. LIFO and Oil examptions should remain. Filed with Sheppard:12O]..
[Helpman:93]
E. Helpman: “Innovation, Imitation, and Intellectual Property Rights”; Econometrica, Vol.61 no.6. Nov.1993,
pp.1247-1280.
[Hemphill:04]‡
Thomas A. Hemphill: Corporate Citizenship: The Case for a New Corporate Governance
Model; Business and Society Review,
Vol.109 no.3, 16 Sep.2004, pp.339-361.
[Henchman:11] Joseph Henchman: Rethinking U.S. Taxation of Overseas Operations: Subpart F, Territoriality,
and the Exception for Active Royalties; The Tax Foundation, 22 Nov.2011
[Henchman:13] Joseph Henchman: Detail of
the Fiscal Cliff Deal; The Tax Foundation, 1 Jan.2011. [xls/taxes]
[HenchmanD:13]‡
Joseph Henchman and Scott Drenkard: North Carolina Tax Reform Optios: A guide
to Fair, Simple, Pro-Growth Reform; Carolina Business Coalition and the Tax
Foundation, Jan.2013. Four well-presented revenue-neutral options, with some
numbers. OIptions A, C, and D eliminate cporpotate taxation. No offshore issues
directly, but implied in eliminating corporate taxation. Affects tax credits.
[HendelMT:08] Anja Hendel, Wolfgang Messner, and Frank Thun (eds.): Rightshore! - Successfully Industrialize
SAP® Projects Offshore; 2008, XVIII, 292 p. 74 illus., Hardcover, ISBN:
978-3-540-77287-3. Have. Comprehensive general quantitative data and experience from
CapGemini on globalization.
[Hendler:02]†
James Hendler et al.: Report on Database Migration for Command an Control;
United States Air Force Scientific Advisory Board, SAB-TR-01-03, Nov. 2002.
[HennessyP:90]†
John Hennessy and David Patterson: Computer Architecture; Morgan
Kaufman, 1990 (3rd Edition 2002). has H&P
rule 5 (factor 1.5-2.0 growth per
year) .
[Henry:12] James S. Henry: The Price of Offshore revisted; The Tax Justice Network USA, Jul.2012, <http://tjn-usa.org/storage/documents/Price_of_Offshore_Revisited_72612.docx>. Estimate $21 to 32 triilion. [ACM]
[Herbert:11]
Bob Herbert: Losing Our Way; The New York
Times, 25 March 2011. bobherbert88@gmail.com
[Herbst:09]
Moira Herbst: “Geniuses at the Gate”; Business
Week, June 8, 2009, p. 14.
[Herbst:11]
Moira Herbst: “Restoring U.S. Competitiveness:
Navigating a Path Forward Through Innovation and Entrepreneurship”; Center for Public Policy Innovation,
Washington, D.C., Sep.7, 2011, section xxiii. R&E credits [xxiv] . Where?
[Heylighen:97]†
F. Heylighen: Occam's razor; in Principia Cybernetica Web, 1997. Also the principle
of parsimony. English spelling:
Ockham. "Entia non sunt multiplicanda praeter necessitatem"
Entities should not be multiplied unnecessarily. Base of Bayes. <http://pespmc1.vub.ac.be/OCCAMRAZ.html>.
Shirley has a [VitaniL:00] reference.
[Heymann:10] Jody Heymann: Profit
at the Bottom of the Ladder; Harvard Business Press, 2010.
[Himmelberg
P:94] Charles P. Himmelberg and Bruce C. Petersen: “R & D and Internal
Finance: A Panel Study of Small Firms in High-Tech Industries”; The Review of Economics and
Statistics, The MIT Press,Vol.76,
No.1, Feb.1994, pp.38-51.
[Hines:96] James Hines:
“Tax Policy and the Activities of Multinational Corporations”; NBER working
paper 5589 (May 1996), pp.25-30
[Hines:04]‡
Corporate Taxation and International Competition?; Ross School of Business paper 1026, Univ. of Michigan, July 2005. <http://ssrn.com/abstract=891233 . Many imbalances Average statutory corporate income tax rates fell from 46% in 1982 to 33% in 1999, though tax bases simultaneously broadened, as a result of which average corporate tax collections actually rose from 2.1% of GDP in 1982 to 2.4% of GDP in 1999. The first is the experience of American multinational firms, whose average effective foreign tax rates fell from 43% in 1982 to 26% in 1999.
“Do Tax Havens
Flourish?”; in J. Poterba (ed.), Tax Policy and the Economy, Vol.19,
National Bureau of Economic Research and MIT Press, 2005, pp.65-100. [xls/taxhavens]
HinesH:90] James R. Hines, jr. and R. Glenn Hubbard: “Coming home
to America: Dividend repatriations by
U.S. multinationals”; in [RazinS:90]‡, 161-200. Financing differences in high tax (debt) and low tax
countries (shares)
[HinesR:94] , James R.
Hines, jr. and Eric M. Rice: ”Fiscal paradise: Foreign tax havens and American
business”; Quarterly Journal of Economics, Feb.1994, Vol.109 No.1,
pp.149-182.
"Tax Havens." In The New Palgrave Dictionary of Economics. 2nd ed., L.E. Blume and S.N. Durlauf (eds.), Palgrave Macmillan, 2008.
[
[HirscheyW:85] Mark
Hirschey and Jerry J. Weygandt: Amortization Policy for Advertising and
Research and Development Expenditures; Journal of Accounting Research, Vol.23,No.1,
Spring, 1985, pp.326-335. 5. R&D
amortization 10-20% advertising 10-20 for non-durable goods and 30-60% for
durable goods, also later [HirscheyW:98] R&D has double the life of
Marketing.
[urgent need for the UK Government to throw money at the road network
HirtlHK:09] Peter B. Hirtle, Emily Hudson, and Andrew T. Kenyon:
Copyright and Cultural Institutions;
Cornell University Library, 2009, <http://ecommons.cornell.edu/handle/1813/14142
Reducing CIT from 28% to 24%.
Hodge:12] Scott
A. Hodge: The Countdown is Over. We’re #1; Fiscal Facts, the Tax Foundation, 1
April 2012.
Japan’s new rate is 38.1% less than the US combined rate of 39.5%. A 10% surtax
will be removed after 2014.
[HodgeM:11]‡
Scott A. Hodge
and William McBride: Beyond
the Headlines: What Corporations Really Pay in Income Taxes. Tax
Foundation Corporate Tax Briefing 2011; Tax Foundation, Slide Presentation to
Congress, 1 Nov, 2011. Tax Foundation slides used on Oct.17th, 2011 for a
Capitol Hill briefing. Uses statutory rates.
[HoefnerRB:11] Michael
Hoefer, Nancy Rytina, and Bryan C. Baker: Estimates of the Unauthorzed
Immigrant Population Residing in the United Staed: Januaru 2010; Population
Estimates, DHS, Feb.2011.
[Hoffelder:12I] Kathleen Hoffelder: “Effective Tax Rate rises for
Industrials”; CFO magazine, 16
Jun.2012. Effective Tax rates up, Three-year ETR for 324 industries 26.3% vs 25.6% prior
period. Only 23 companies had cridots
for domestic manufacturing or R&E,
[Hoffelder:12R]‡ Kathleen Hoffelder: “The Second Greatest Risk”; CFO magazine, 1 Aug.2012. Transfer
pricing.
[.
[Hoovers:10]
Hoovers: Company Information: Need it? We’ve got it; retrieved 2010 <http://www.hoovers.com/> a subsidiary
[Holmes:04]
Oliver Wendell Holmes: `Taxes are what we pay for a civilized economy’.
[HoltzEakin:11]
Douglas Holtz-Eakin: The Budget Deal, Tax Policy, and Carried Interest; The
National Review, 20 July 2011. Critiques taxation of carried interests. Data on partnerships. Nearly Diatribe.
[HongS:05]
, Qing Hong and Michael Smart: “In Praise of Tax Havens: International Tax
Planning and Foreign Direct Investment”;
Mimeo, University of Toronto, 25 May 2005.
[HoopesMP:12]‡
Jeffrey L. Hoopes, Devan Mescall, and Jeffrey A. Pittman: “Do IRS Audits Deter
Corporate Tax Avoidance?”; The Accounting
Review, Sep 2012, Vol.87 no.5, pp.1603-1639. doi: http://dx.doi.org/10.2308/accr-50187.
[Hoppel:13]
Adrian Hoppel: Law and defense: Rand Paul Comes to the defense of Apple; MacLife,
22 May 2013.
[Hosaka:11]‡
Tomoko A. Hosaka: Olympus Chairman Stepping down amid Scrutiny; Bioscience
Technology, 26 Oct.2011. Advisors normally get 102% of a deal, Olympus UK paid
over a third of $2B.
[Howard:03]‡
Philip K. Howard: “Yes, It’s A Mess- But Here’s How to Fix it"; Time
Magazine, June 2, 2003. CWD-grassroots: The Truth About Philp Howard’s
“Common Good”; The Foundation for Taxpayer and Consumer Rights, 14
Jan.2004. Howard only wants to get rid of Lawyers
and Juries. <http://cwd.grassroots.com/corporate/rp/4152.pdfl>.
[HP:08]‡
HP-1060, Statement For the Record of the
Senate Committee on Finance Hearing on International Tax Reform (June 26,
2008).
[HR:85]‡ A Study of
Intercompany Pricing Under Section 482 of the Code, 1988-2 C.B. 458 (1988) (“White Paper”). Cited in CIP:05 <The legislative history plainly intends that
the IRS may make periodic adjustments as a contingent royalty when the taxpayer
provides for only an inadequate lump sum. See H.R. Rep. 99-426 at 424-25 (1985),
Refers to Chapoton>.
[Houlder:10B] Vanessa Houlder: “OECD Hails tax haven crackdown “; Financial Times, 19 Jan.2010.
[Houlder:10C] Vanessa Houlder: “Tax haven Drive will mean greater
scrutiny”; Financial Times, 20 March
2010. Chinese
G’vmnt uses information to stop taxhaven
transfers.
[Houlder:11] Vanessa
Houlder: “Secrecy Under Scrutiny: Pressure for
transparency persists as havens yield billions for G20 treasuries”; Financial Times, 12 Jan.2011. Effect of
amnesty after release of names of individuals from banks in Liechtenstein etc.
[HoulderMG:11] Vanessa
Houlder ,Megan Murphy, and Jeff Gerth: Did Barclay’s Help U.S. Banks Get
Undeserved Foreign Tax Credits?”; Financial Times, 25 Sept.2011.
[HousemanR:09] Susan N. Houseman and Kenneth R Ryder, jr (eds.):
Measurement Issues Arising from the Growth in Globalization; Conference papers,
National Academy of Public Administration, 6 Nov, 2009, 16 papers, 421 pp.
[Howard:95] Philip K. Howard: The Death of Common Sense; Random House,
1995. Reprinted 2011. also see Steve
Clemons, The Daily Show, 3 May 2011, <http://www.thewashingtonnote.com/archives/2011/05/the_death_of_co/; CWD-grassroots: The Truth About Philip Howard’s “Common Good”; The Foundation
for Taxpayer and Consumer Rights, 14 Jan.2004.
Howard only wants to get rid of Lawyers and Juries. <http://cwd.grassroots.com/corporate/rp/4152.pdfl> [not cited]
[Howard:01] Philip K. Howard: The
Collapse of the Common Good; Updated
version of: The Lost Art of Drawing the Line; Random House, 2001.
[Hsieh MG:03] Ping-Hung Hsieh , C.S. Mishra, and D.H. Gobeli: “The return on R&D
versus capital expenditures in pharmaceutical and chemical industries”; IEEE Transactions on and Engineering
Management, May 2003, Vol.50 no.2 ,
pp.141 – 150. 20% on operating margin/Tobin’s Q.
[Hsueh:11]‡ Roselyn Hsueh: How China
Outsmarted the WTO; RegBlog, Univ.of Pennsylvania Law School, 26 Dec.2011.
[Hubbard:92] Glenn Hubbard: Integration of the Individual and Corporate Tax Systems: Taxing Business Income Once; US Treasury report, 1992. Led to CBIT and Bush:05 plan. Equal taxation of all businesses.
[Hughes:07]‡
Gordon Hughes: Hard Drive; 2007. On Kindle, about
Xerox etc.
[HuizingaG:03]
Harry Huizinga & Nicodeme Gaetan:" Foreign Ownership and Corporate Income Taxation: An Empirical
Evaluation“; CEPR
Discussion Papers , 2003. 3952,
C.E.P.R. Discussion Paper 3952; Public
Economics 0310005, EconWPA ; European
Economy - Economic Papers 185,
Directorate General Economic and Monetary Affairs, European Commission; European
Economic Review, Elsevier, Vol.50(5),
pp.1223-1244, July.
[HuizingaN:97]
Harry Huizinga and Soren Bo Nielsen: “Capital income and profit taxation with
foreign ownership of firms”; Journal of
International Economics, Feb.1997, 42 (1-2), 149-165.
Hulten:06] Charles
Hulten: Intangible Capital and Economic Growth; National Bureau of Economic
Research (NBER), Working Paper 11948, Jan.2006, <http://papers.nber.org/tmp/16760-w11948.pdfl>.
[Hummels:07] David Hummels: “Transportation Costs and International
Trade in the Second Era of Globalization”; Journal
of Economic Perspectives, Summer 2007, Vol.21 no.3, pp.131-154.
[Hungerford:11] Thomas L. Hungerford: Tax Expenditures and the Federal Budget;
Congressional Research Service, RL34622, 1 June 2011. By FY2007, discretionary spending was
approximately equal to the estimated revenue loss of tax expenditures (about
7.6% of GDP); reduced after 1986 act to 1989. And about 7% of GDP in 2011,
23.8% of total expenditure. Similar to Hiungerford:08? About $1T [xls/taxes] ,
[Hungerford:12]‡ Thomas L. Hungerford: Taxes and the Economy: an Economic Analysis of the Top Tax Rates Since 1945; Congressional Research Service, R42729, 14 Sep.2012. Experience from changes in high-level tax rates There is no conclusiveevidence that the top tax rates have little aocciciation with saving, investment, or productivity growth. It does affect imcome distribution. Withdrwn due to political pressures. Has Graphs of actual tax rates.
[Hunt:12] Al Hunt: “A Budget Band-Aid on Corporate Taxes”; Bloomberg Businessweek, 20 Feb.2012,
p.10. Clumsy
solution, tax expenditures $210B over 10 years. [xls/taxexpenditures]
[Huntsman:11] John
Huntsman: “Time to Compete”An American Jobs Plan; Gov. Huntsman, 31 Aug.2011. Original title in 61pt font. Both tax-free
repatriation of $400 to $600B and no dividends or capital gains tax. 25%
corporate tax, Territorial
[HurstP:11] Erik Hurst and Benjamin Wild Pugsley: What Do Small Businesses Do?; Brookings Papers on
Economic Activity Conference, Aug.2011. Authors are at the University of Chicago. Useful tables and
graphs. See comment by [Litan:11]‡.
[
[IBA:04]‡
Institute of Business Appraisers: Glossary. <http://go-iba.org/who.asp, Plantation, FL 33318, 2005. Premise of Value – an assumption as to whether a business enterprise
or intangible asset will be valued in liquidation or as a going concern.
[Ibbotson:04] Ibbotson Associates: Stocks, Bonds, Bills, and Inflation; 2004 Yearbook, Wiley. The risk premium for 1926 through 1999 historic averages att
of 8.1 percent ’ Cost of
Capital 2000 Yearbook 34 states: “In all of the beta regressions, the total returns of
the S&P 500 are used as the proxy for the market returns. The series used
as a proxy for the risk-free asset is the yield on the 30-day T-bill”;
[IBM:11]‡ IBM Canada: Monitor. Manage, Perform.; IBM
Software Group White paper, 2011. Referred to by (an updated version of [VBM:04]‡
[IEEE:98]‡
IEEE Standard for Software Maintenance; Document 1219-1998, issued 1998. Section 3 contains definitions for adaptive,
corrective, emergency, and perfective maintenance. These four categories cover
all of software maintenance.
[IFPUG:02]†
International Function Point Users group: IT Measurement, Practical Advice
from the experts; Addison-Wesley 2002.
[ILO:11] International Labour Organization: Key Indicators of
the Labour Market, 7th Edition; ILO Publications, Geneva,
Switzerland, 2011.
[Immelt:11] Jeffrey H. Immelt: Growth Starts Here, GE 2010 Annual
Report; General Electric Corporation, 25 Feb.2011.
[Immelt:11I]‡ Jeff Immelt: GE’s interview; 20 Oct. 2011,
<http://www.reuters.com/video/2011/10/20/ges-jeff-immelt-how-the-us-can-win?videoId=223718261
>.
[ImmeltEa:11] Jeffrey Immelt, chair, The Jobs Council: Taking Action, Building
Confidence”; Interim Report to the President, The President’s Council on Jobs
and Competitiveness , 10 Oct.2011, <http://www.jobs-council.com/2011/10/10/jobs-council-releases-taking-action-building-confidence-interim-report-to-the-president/. Five initiatives: 1. Infrastructure, 2. Nurture Enterprises,
3. reverse FDI outflows, 4. Simplify regulatory review, 5. Develop talent.
Mentions only IP protection. But capital is mentioned 48times.
[Interbrand:07] Interbrand: The 100 Top Brands; Business Week, 6 Aug.2007.
[IPRA:03]‡
International Property Research Association: Royalty Rates for technology, 3rd
edition; 2003;
[IRC-11:50]
Dept.of the Treasury: USC Title 26, §11: Tax imposed ; based on The yyyy Act of 1984; US House of
Representatives H.R.tttt, Public Law lll, date. Establishes corporate taxation.
[IRC-41:85]
Dept.of the Treasury: USC Title 26, §41: Credit for increasing research
activities ; based on The yyyy Act of
1984; US House of Representatives H.R.tttt, Public Law lll, date
[IRC-61:85]
Dept.of the Treasury: USC Title 26, §61: Gross income defied ; based on The yyyy Act of 1984; US House of
Representatives H.R.tttt, Public Law lll, date.
[IRC-367:84]
Dept.of the Treasury: USC Title 26, §367: Foreign Corporations; based on The
Deficit Reduction Act of 1984; US House of Representatives H.R.4710, Public Law
98-369, 18 July 1984. used USC 936 (h)(3)(B) for the definition of intangle
property. See [Rostenkowski:84].
[IRC-482:85]
Dept.of the Treasury: USC Title 26, §482: Allocation of income and deductions
among taxpayers ; based on The yyyy Act of 1984; US House of
Representatives H.R.tttt, Public Law lll, 1985. The main law fro transger pricing,
only one paragraph, the rest is defined by regulations [IRSregs-482].
[IRC-901:85]
Dept.of the Treasury: USC Title 26, §901: Taxes of foreign counries and of
possessions; based on The yyyy Act of 1984; US House of Representatives
H.R.tttt, Public Law lll, date. Limits IRC 904.
[IRC-904:85]
Dept.of the Treasury: USC Title 26, §904: Limnitiation on credit; based on The yyyy
Act of 1984; US House of Representatives H.R.tttt, Public Law lll,
[IRC-936:75] Dept.of the
Treasury: USC Title 26, §367: Puerto
Rico and possession tax credit; based on
The xxx Act of 1984; US House of Representatives H.R.nnnn, Public Law llllll, 1975. Defines US nearshore taxhavens. Prrovides the
definition of intangible property.
IRS-400:08]‡ The 400 individual Tax Returns Reporting
the Highest Adjusted Gross incomes Each Year, 1992-2203. IRS,
<http://www.irs.gov/pub/irs-soi/07intop400.pdfl>
[<http://www.irs.gov/pub/irs-pdf/i1120.pdf>
<http://www.irs.gov/pub/irs-pdf/i1040.pdf>
IRS-199:12] IRS: Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements; <http://www.irs.gov/businesses/article/0,,id=253819,00.html>
<http://www.irs.gov/publications/p537/>
Coordinated Issue paper – Sec. 482
CSA Buy-in Adjustments (CIP); IRS
LSMB, 27,
Sep.2007, updated 30 Jan.2012, http://www.irs.gov/businesses/article/0,,id=174320,00.html, also see [ITS-TP:12]
"Treasury
Conference on Business Taxation and Global Competitiveness". US Treasury. pp 42. 23 July 2007.
<http://www.irs.gov/pub/irs-soi/02corate.pdfl>
IRS-ED:10] IRS:1500
attorneys in Office of the Chief counsel. 290 in LMSB in DC, PA NY IL
TX CA [xls/irs]‡
[
IRS-FR:93] IRS: The Final Regulations; A review of Comparability
under the 1993 482 regulations; <http://www.irs.gov/pub/irs-apa/comparable_selection_data.pdfl> . Refers to Standard & Poor’s, Moody’s, several other
databases.
{IRS-FT:11]‡ IRS: Treasury and IRS Issue Guidance Outlining Phased Implementation of FATCA Beginning in 2013; IR-2011-76, 14 Jul.2011, <www.IRS.gov/newsroom>.
[IRS-IRM:12] IRS Internal Revenue
Manual; <www.irs.gov/irm>
<http://www.irs.gov/businesses/corporations/article/0,,id=171443,00.html>. UTP rules.
[IRS-LMSB:03]‡ Transfer Pricing Compliance Process, 22
jan 2003,
<http://www.irs.gov/businesses/international/article/0,,id=156262,00.html>
;
[<http://www.irs.gov/pub/irs-trty/model006.pdfl>
[IRS-OIC:11]‡ IRS Chief
Counsel: Disclosure and Privacy Law Reference Guide (§6103); pub. 4639, Sep.
2011, 331pp. History. Corporate records public to 1909, 1913 to 1977, when internal
limits
[IRS-PM:08]‡
IRS Performance Measures 2008 Data Dictionary; IRS, 2008, <http://www.irs.gov/pub/irs-utl/2008_measures__data_dictionary_02042008.pdfl> . 266 pages
<http://www.treasurydirect.gov/govt/rates/tcir/tcir_opdprmt2.htm
Mill
IRS-PS:96] IRS: Internal Revenue Service Simplification of Entity
Classification Rules ; PS-43-95, 9
May 1996. This
document contains proposed regulations that would replace the existing
regulations for classifying certain business organizations with an elective
regime. These proposed regulations simplify the existing classification rules.
Pertains to Check-the-box rules
[IRS-QV:11] Qualified Alternative Fuel Motor Vehicles (QAFMV) and
Heavy Hybrid Vehicles; IRS, Businenss Topic, 10. Jan 2011.
[IRS-RRA:98] Internal
Revenue Service, Restructuring and Reform Act of 1998 (RRA 98), Pub. L. No.105-206,
112 Stat. 685, 1998. changed allocation.
[IRS-SC:12] IRS: SOI Tax Stats
– Corporation Source book; IRS Statistics Office, for 2009 and prior years, 26
Apr.2012, http://www.irs.gov/taxstats/article/0,,id=165716,00.html
[IRS-SI:12] IRS:
SOI Tax Stats – Individual Income Tax Returns; IRS Statistics Office, report
1304 for 2009 and prior years, 3 Aug.2012, <http://www.irs.gov/taxstats/indtaxstats/article/0,,id=134951,00.html>#_pt2
[IRS-SPPI:09]‡ [xls/irs]
Income, Internal
Revenue Service, 2011. Index to data and downloads.
ww.irs.gov/pub/irs-soi
ase date 13 Feb 2009. They are all IP, unless tainted.
[IRS-TF:12]‡ IRS: The Tax gap for the year 2006,
overview. $450B. Corp. non-reporting $122B
business income on individual returns, 48B large corps, 18B small corps.
http://www.irs.gov/pub/irs-ews/
25 Jan 2008 (30.5.2.5) on foreign travel has been deleted as of 7 Feb.2012
[IRS-TI:09]‡
IRS: Transactions of Interest; IRS Revenue Bulletin 2009-31, 3 Aug.2009. Notes about tax
abuse, manly for individual taxes.
[IRS-TI:11]‡ IRS
tax information for corporations: FASB Interpretation No.48, Accounting for
Uncertainty in Income Taxes; IRS, 17 March 2011
[IRS-TP:88]‡
IRS: A study of Transfer Pricing under Section 482 of the Code; Oct 1988. = [Chapoton:88]‡
[IRS-TP:94] IRS: Regulations on Transfer Pricing, Methods to
Determine Taxable Income In Connection with a Transfer of Intangible Property;
U.S. Internal Revenue Service: Title 26 Chap.I Subchap.A Part 1 §1.482-4, 8
Jul.1994; amended 4 Aug.2006, Federal
Register, Vol.71 no.150, pp.44479-44519.
[IRS-TP:04] IRS: Studies
into transfer pricing rules, Income Tax Treaties, and Corporate Expatriation, amendments to IRC § 482; US
Congress, Subsec.806, Pub.L.108-357, 2004.
[IRS-TP:07]‡
Transfer Pricing; 28 Nov 2007.
[IRS-TP:12] Regulations on Transfer Pricing, Methods to Determine
Taxable Income In Connection with a Cost Sharing Arrangement; U.S. Internal
Revenue Service: T.D. 9568, 19 Mar.2012. In Federal Register and effective Dec.2011,
Plattforms, PCT versus CST.
[IRS-TT:10]‡
IRS: United States Income Tax Treaties - A to Z;
[IRS-TS:06] IRS: Final report on Treatment of Services under Section 482--9T; Aug.2006, 189pp. CostPlusMethod, <http://www.irs.gov/businesses/international/article/0,,id=96739,00.html>
http://www.irs.gov/businesses/international/article/0,,id=96739,00.html
[IRSregs367:84]
Internal Revenue Service: Regulations on Transfer to Foreign Corporations subject
to section 367(a); Title 26 Chap.I Subchap.A Part 1 §1.367, effective Dec.
1984. See
[Rostenkowski:84]
[IRSregs367:99]
Internal Revenue Service: Regulations on Transfer to Foreign Corporations.I
Subchap.A Part 1 §1.367(d)-1T(c)(1), Use CFR `1-482 principles to define
intangible transfers. effective Dec. 1984. See [Rostenkowski:84]
[IRSregs482-1:94]‡
Internal Revenue Service: Regulations on Transfer Pricing, Allocation of income
and deductions; Title 26 Chap.I Subchap.A Part 1 §1.482-1, 1994.
[IRSregs482-3:95]‡
Internal Revenue Service: Regulations on Transfer Pricing, Methods to determine
taxable income in connection with a transfer of tangible property; Title 26
Chap.I Subchap.A Part 1 §1.482-3, 1995.
[IRSregs482-4:94]‡
Internal Revenue Service: Regulations on Transfer Pricing, Methods to determine
taxable income in connection with a transfer of intangible property; Title 26
Chap.I Subchap.A Part 1 §1.482-4, 1994b.
[IRSregs482-5:94]‡
Internal Revenue Service: Regulations on Transfer Pricing, Comparable profits
method; Title 26 Chap.I Subchap.A Part 1 §1.482-5, 1994.
[IRSregs482-6:95]‡
Internal Revenue Service: Regulations on Transfer Pricing, Profit split method;
Title 26 Chap.I Subchap.A Part 1 §1.482-6, 1995.
[IRSregs482-7(c):96]‡ T.D. 8670; 18 Sep.1996
Revision of Section 482 Cost Sharing Regulations. These regulations eliminate the active conduct rule of
_1.482-7(c) as a requirement for qualification as a controlled participant in a
qualified cost sharing arrangement.
Section 1.482-7(c)(1) of these regulations substitutes a general rule
that a controlled taxpayer may be a controlled participant in a cost sharing
arrangement only if it reasonably anticipates that it will derive benefits from
the use of covered intangibles. In
addition, _1.482-7(f)(3)(ii) provides that if a controlled participant
transfers covered intangibles to another controlled taxpayer, the participant's
benefits will be measured with reference to the transferee's benefits rather
than with reference to any consideration paid by the transferee. (This gives rise to results similar to those
under the subgroup rules of the proposed regulations by different
mechanics.) Finally, _1.482-7(f)(3)(ii)
continues to provide that the amount of benefits that each of the controlled
participants is reasonably anticipated to derive from covered intangibles must
be measured on a basis that is consistent for all such participants.
[IRSregs482-7:01]‡
Internal Revenue Service: Regulations on Transfer Pricing, Sharing of costs;
Title 26 Chap.I Subchap.A Part 1 §1.482-7, 2001.
[IRSregs482-8:94]‡
Internal Revenue Service: Regulations on Transfer Pricing, Examples of the best
method rule; Title 26 Chap.I Subchap.A Part 1 §1.482-8, 1994.
[IRSregs936-6b:96]‡
Internal Revenue Service: T.D. 8669
10/8/1996 Computation Of Combined Taxable Income Under the Profit Split Method
When the Possession Product Is a Component Product or an End-Product Form for
Purposes of the Possessions Credit Under Section 936
(ITEP)
Institute on Taxation and Economic Policy, Study Finds Resurgence in Corporate
Tax Avoidance, 19 Oct.2000, pp.1-3.
[Jackson:10] James K. Jackson: Outsourcing and Insourcing Jobs in the U.S. Economy: Evidence based on Foreign Investment; Congressional Research Service, Report for Congress, Cornell University, 15 April 2010. Data specific for multinational corporations and their affiliates, outsourcing, productivity, employment over time, intrafirm trade, sales, R&D,
[Jacobs:10]‡
Vernon K. Jacobs: The Tax Reform
Alternative, Txation, Inflation, and Expatriation; Offdshore Press Incs,
Prarie Village KS. Discrimnatory taxes. Elimnate all income taxes, Move to a consumption tax.
No double tax on cororate profits. Discusses Flat, fair, Sales taxes (best?)
VAT taxes, The solution is to move offshore!
[Jacobs:12]
Deborah L. Jacobs: The Best Foreign Retirement Havens; Forbes, 21 Nov 2012
[JanebaP:99]‡
Eckhard Janeba and Wolfgang Peters: “Tax Evasion, Tax Competition, and the
Gains from Nondiscrimination: The Case of Interest Taxation in Europe”; The Economic Journal, Vol.109:, 199, pp.93-101.
[JanebaS:03] Eckhard Janeba and Michael Smart: “Is
Targeted Tax Competition Less Harmful than its Remedies?”; International
Tax and Public Finance, Vol.10, 2003, pp.259-280. Uses immobile for tangible and mobile for capital and
intangible assets.
[JCT:84]‡ Joint Committee
On Taxation: General Explanation of the
Revenue Provisions of the Deficit Reduction Act of 1984; US Congress, JCS-41-84,
31 Dec.1984 ([Rostenkowski84]).
[JCT:03] JCT:
Report of the Joint Committee on Taxation Relating to the Internal Revenue
Service as Required by the IRS Reform and Restructuring Act of 1998; Joint
Committee on Taxation, 20 May 2003, 174pp., Modernization, recruitment, staff p.64, p160.
Corporate Tax shelters p.5-6, Audit 5,7 32, 36, 85, unauthorized inspection of
returns (§1203) p.9, 128-129, p.156 tax gap $280B and growing, Data on hrs/return
corps and large corps p106 , Cycle days large corps 567 p.140. 80% need change
p.141. appeals 250, tax court p151. Top salaries, with priors. p132. Tenure p.134.
[JCT:06] Joint Committee
on Taxation: The
Impact of International Tax Reform: Background and Selected Issues Relating to
U.S. International Tax Rules and the Competitiveness of U.S Businesses; JCT report
JCX-22-06,
21 June 2006. World-wide vs. Territorial.
[JCT:08]‡ Joint Committee
On Taxation: A reconsideration of Tax expenditure Analysis ; JCX 37-08, 12 may
2008. Tax subsifies are tax provisons that
are “deliberately inconsistent with an identifiable general rule of the present
tax law” quted by Hungerford:11]‡
[JCT:10] Joint Committee on Taxation: Present Law and
Background Related to Possible Income Shifting and Transfer Pricing; JCT report
(JCX-37-10, 20 July 2010. Section 936
Conversions-p.37.
[JCT:11] JCT:
Tax Incentives for Research, Experimentation, and Innovation; Joint Committee
on TaxationR&E §174. Compares other countries.forms get most (table 3) Complex,
compliance cost.; and JCT: Background Information on TaxExpenditure
Analysis and Historical Survey of Tax Expenditure Estimates; Joint Committee on
Taxation JCX-15-11, 28 Feb.2011, 37pp. and JCX-45-11, 16 Sep.2011.
[JCT:11P]‡ Joint Committee
On Taxation: Description of Revenue
Provisions Contained in the President’s Fiscal Year 2012 Budget Proposal; US
Congress, JCS-3-11USPO, June 2011. Deferral (p.161, property transfers p.218.
[JCT-12:12] JCT: Selected Issues Relating to Choice of
Business Entity; Joint Committee on Taxation, 27 July 2012, JCX 66-12, 88pp.C-corps vs
LLCs , pass-throughs . data 22.6 soleprops, 1.7M C-corps, 1.9m farms, 3.1 LLC,
4.1m S-corps.(since 1958) . Growing in all sizes, but more stable since 2003.
In HMAT.xlx Corptax, Uniform pass-through. Large c-corp – large S corp by 2003
[JCT-18:12] JCT: Overview of the Federal Tax System as in Effect
for 2012; Joint Committee on Taxation, 24 Feb.2012, JCX 66-18, 32pp. Good description
with data.
[Jefferson:1816]‡ Thomas
Jefferson, 1816 “I hope we shall... crush in its birth the aristocracy of our
moneyed corporations which dare already to challenge our government in a trial
of strength, and bid defiance to the laws of our country”; <<check>>
[JefferySO:88] David
Jeffery, Brian Sturgeon, and Michael O’Brien:
Tolley's Tax Investigations; Tolley Publishing, 1988.
[Jenkins:11]‡ Holman W. Jenkins, jr.: “Chicago Economics on Trial”; WSJ,
25 Sep.2011. Talk be
Robert Lucas.
The New York
Times, 17
[JensenM:76]‡ Michael
Jensen and William Meckling: “Theory of the Firm: Managerial Behavior, Agency
Costs and Ownership Structure”; Journal
of Financial Economics, 1976. Deinning:11: shareholders are the principals of the
firm—i.e., they own it and benefit from its prosperity, while the executives
are agents who are hired by the principals to work on their behalf.
[JensenM:11] Mathew H. Jensen
and Aparna Mathur: “Corporate Tax Burdens on Labor: Theory and Empirical
Evidence”; Tax Notes, 6 June 2011. Employees’s wages are lowered because
of the CIT per [Harris:09]‡. Critiques many prior analyses and observations. Mixed
results, but employees seem to be affected.
[Johnson:01]†
Justin P. Johnson: The Economics of Open Source Software; MIT, http://opensource.mit.edu/papers/johnsonopensource.pdf., retrieved 2001.
[Johnson:05R]‡ Calvin H.
Johnson: Can the IRS be well liked?, Rossotti’s Many Unhappy Returns; Tax
Notes, Tax Analysts, 2005. Remaining problems not addressed
[
Johnson:05V]
Erinn R. Johnson: "A $13.5 billion merger between Symantec Corp. and
VERITAS Software Corp"; Black Enterprise, 2005. 13.5M , later
valued at 11B, actually paid 13.2
[
Tax Notes, Vol.117, 10 Dec. 2007,
pp.1082.
[Johnson:12]‡ Sarah Johnson: “More Vitriol Aimed at Obama’s Tax Plan”; CFO magazine, 7 Mar.2012. Changes in taxation of pass throughs may again
reconsider their structure. Also LIFO. ransfer pricing.
[Johnston:98]‡ David Cay Johnston: Behind IRS hearings, a GOP plan to End the
Tax Code; The New York Times, 4 May
1998. Quotes
Harberger and later papers that put more of the burden of the corporate tax on
labor.
[Johnston:02]‡ David Cay Johnston: “IRS audits of Working poor increase”; NYT , 1 March 2002.
[IRS
unaware of many tax fraud techniques p2.
Audit as an option value p 168. Inversion p238. Jonathan Blattmachr
p264. Congress unaware p294. Rossotti final report on audits p296. Audits down
p298. Trust in ATA p300. Archer: pull it out by its roots p.301.
[Johnston:03E]‡
David Cay Johnston: “Tax Moves by Enron Said to Mystify the I.R.S.”; The New York Times, 13 Feb.2003. The IRS and Enron "Enron
and other big companies have escaped taxes in recent years through financial
maneuvers so complex that the Internal Revenue Service has been unable to
understand them," and that these transactions, while legal, "create
[undisclosed] risks for shareholders"
[Johnston:07]‡ David Cay Johnston: Free Lunch: How the Wealthiest Americans
Enrich Themselves at Government Expense, (and StickYou with the Bill); Reed Elsevier, 2007, Portfolio Trade, 30 Dec.2008. Remy Welling, an
Internal Revenue Service investigator who blew the whistle on improper tax
breaks for the wealthy and lost her job. Review: no solutions at all.
Settlemnts sealed p.198.
[Johnston:09] David Cay Johnston: Donald C. Alexander, 87, Who Resisted Nixob
at I.R.S., Is Dead; NYT, 8 Feb. 2009.
IRS Commissioner 1973 to 1977. “prissy about legal
procedure”.
[Johnston:11]‡ David Cay Johnston: First Look at US Pay
data, it’s awful; Reuters, 19 Oct
2011, based on [SSN:11]‡; Reuters Video:
U.S. median wage lowest since 1999; 20 Oct 2011, <http://www.reuters.com/video/2011/10/20/ges-jeff-immelt-how-the-us-can-win?videoId=223692500&refresh=true .
[Johnston:12]
David Cay
Johnston: “Congress’ Potential Faulty
Tax Logic”; The National Memo, 3
March 2012. Lowering corporate tax should cause
dividend rates to go up to counteract wage depression per [HasettM:10]‡.
[Johnston:12B]‡ David Cay Johnston: The Richest get Richer; The National Memo; also Reuters,15 March 2012. Compares 1933 and 2010.
[JohnstonW:11] Louis
Johnston and Samuel H. Williamson: What Was the U.S. GDP Then?; MeasuringWorth,
2011. URL: <http://www.measuringworth.org/usgdp/ GDP data,
[JollyK:12] David
Jolly and Brian Knowlton: “5 European nations Agree to Help U.S. Crack Down on
Tax Evasion”; The New York Times, 8
Feb 2012. part of FATCA Foreign Account Tax Compliance
Act, part of a 2010 jobs bill. (France, Germany, Italy, Spain, and UK), not
Switzerland, Canada, China, Japan.
[Jones:95]‡† Capers Jones: "Backfiring: Converting
Lines of Code to Function Points"; IEEE
Computer, Vol.28 no.11, Nov.1995,
pp.87-88.
[Jones:96] Capers
Jones: Applied Software Measurement: Assuring Productivity and Quality;
McGraw-Hill, 1996.
[Jones:05]‡
Charles I. Jones, 2004. "Growth and Ideas“; NBER Working Papers 10767, National Bureau of Economic Research, Inc.; Handbook
of Economic Growth, in: Philippe
Aghion & Steven Durlauf (ed.), Handbook of Economic Growth, edition 1, Vol.1,
chapter 16, Elseviers, pp.1063-1111.
[Jones:97]†
T. Capers Jones: Software Quality -- Analysis and Guidelines for Success;
International Thomson Computer Press, Boston, 1997.
[Jones:97]†
T. Capers Jones: Applied Software Measurement: Assuring Productivity and
Quality; Prentice Hall - PWS. 1997
[Jones:98]† T.
Capers Jones: Estimating Software Costs; McGraw-Hill, 1998.
[Jones:13]‡
Sam Jones: Cayman Islands to open to scrutiny; Financial Times, 16 Jan 2013. {VIC Ch6.1}
[JonesCNDG:13] Robert P.
Jones, Daniel Cox, Juhem Navarro-Rivera, E.J. Dionne, Jr. and William A. Galston: Do Americans Believe Capitalism &
Government Are Working? Findings from the 2013 Economic Values Survey by
the Public Religion Research Institute and Governance Studies at Brookings,
18 Jul.2013. Overall half do
[Jopson:05]‡
Barney Jopson: “Global standards: A challenge not yet surmounted ”; Financial Times, 7 Sep.2005. David Tweedie One set of financial accounting rules.
[JorgensonLN:06]‡ Dale W. Jorgenson, J. Steven
Landefeld, and William D. Nordhaus, eds.: A
New Architecture for the U.S. National Accounts; Studies in Income and Wealth, Vol.66,
Chicago: University of Chicago Press, for the National Bureau of Economic
Research, 2006.
[JorgeS:90]‡
Antonio Jorge, Jorge Salazar-Carrillo: Lucrum Cessans, Damnum Emergens and the
Market Place; Journal of Forensic
Economics: Winter 1990, Vol.4 no.1, pp.117-118. : Lucrum Cessans= Lost profits, Damnum Emergens = Actual losses.
Concepts in French law. The term foregone
profits is, indeed, an ambiguous one. Strictly speaking, it is a
conceptual category radically alien to the logic of economics itself.
[Joseph:13]
Mathai Joseph: Digital Republic, India’s Rise to IT Power, History and Memoir:
Power Publishers, 2013. On Kindle & cloud
[Jovanovich:02] Juan Martin Jovanovich: Customs Valuation and Transfer
Pricing: Is It Possible to Harmonize Customs and Tax Rules?; Kluwer, Series on International Taxation, 2002.
[Jussawalla:92] Meheroo Jussawalla: The Economics of Intellectual Property in a World Without Frontiers;
Praeger/Greenwood, 1993. Fujitsu-IBM case, p.113.
[Kahn:12] Jeremy Kahn: Malta Lures Hedge
Funds with 300 Days of Sunshine; Bloomberg
Markets Magazine, 10 Jan 2012. As of early November, the number of funds located in
Malta had grown to more than 500 with 8 billion euros ($10.7 billion) under
management from 165 funds with less than 5 billion euros under management in
2006, according to the Malta Financial Services Authority(MFSA). {VIC Ch6.3.1}
[Kaiser:09] Robert G. Kaiser: So
damn Much Money; Knopf, 2009. On lobbying, lobbyists and Congress. {VIC Ch8.2.2}
[KakaKS:06]‡
Noshir F. Kaka, Shailesh S. Kekre, and Saipriya Sarangan: “Benchmarking
India's business process outsourcers”;
McKinsey Quarterly, July 2006. {VIC Ch6.4}
[KamiyamaSM:06]‡
S. Kamiyama, J.Sheehan, and C.Martinez: “Valuation and Exploitation of
Intellectual Property”; STI Working Paper 2006/5, 2006, Statistical Analysis of
Science, Technology and Industry. <http://www.oecd.org/sti/working-papers>. {VIC Ch4.0}
[Kampas:03]‡ Paul J.Kampas: “Shifting Cultural Gears
in Technology-Driven Industries” MIT Sloan management review, 15 Jan 2003, also
a chapter in Edgar Schein, et al.,DEC
is Dead, Long Live DEC”; . technology-driven companies need to shift from
a product-innovation culture to a process-innovation culture as their
markets mature. {VIC Ch3.5}
[Kan:03]†
Stephen Kan: Metrics and Models in Software Quality Engineering;
Addison-Wesley 2003. {VIC Ch5.1, M4 }
[KangN:12] Samuel
S. Kang and Tuan S. Ngo: Top U.S. Tech Companies’ Tax Avoidance Can Be
Mitigated, Report Says; Tax Notes Today,
Tax analysts. 18 April 2012. 30 high tech companies; based on [KangN:11]‡ Samuel S. Kang
and Tuan Ngo: “Corporate America Untaxed: Tax Avoidance on the Rise"; Greenlining Institute, 2011. The report finds
that U.S. Fortune 100 companies "avoided $60 billion in taxes by shuttling
profits offshore”; Expanded on [GAO:08]‡. {VIC Ch9.3.2}
[Kao:07] John Kao: Innovation
Nation, How America is losing its innovation edge, why it matters, and what we
can do to get it back; Free Press, 2007. Have. reviewed by Stine Grodal in Science, Sep.2008.
{VIC Ch5.1, }
[KaplanN:07]‡†
Robert Kaplan and David Norton: Using the Balanced Scorecard as a Strategic
Management System; Harvard Business Review; Jul.2007; first published
Jan.1996. {VIC Ch5.1-M5}
[KaplanN:04] Robert S. Kaplan and David P. Norton; Strategy
Maps: Converting Intangible Assets into Tangible Outcomes, Harvard Business
School Press, 2004.
[Kaplow:99] Lois Kaplow:Tax complexity and
enforcement; in [Slemrod:99]
. p.389 – effect of weak enforcement. Does not consider
IRS limits
[KarC:09] Dev Kar and Devon
Cartwright‐Smith: Illicit Financial Flows from Developing
Countries: 2002‐2006; Executive Report, 2009, Global Financial
Integrity, Center for International policy, www.gfip.org. From
Vaibhav CS207.
[Kaufman:07]‡
Wendy Kaufman: Random Tax Audits Return to the U.S.; NPR. 9 Oct.2007. $345B uncollected.
[Rosato:07] is better. [xls/irs]
[Keating:10]
David Keating: A Taxing Trend: The
Rise in Complexity, Forms, and Paperwork Burdens; National Taxpayers Union,
NTU Policy Paper 127, April 15, 2010.
[Keen:01] Michael Keen: “Preferential
Regimes Can Make Tax Competition Less Harmful”;
National
Tax Journal, vol.54, 2001, pp.757-762. Compares two symmetric countries, and shows that tax
revenues will decrease. But does not consider Double Irish nor fairness.
[KellerY:03] Wolfgang
Keller and Stephen R. Yeaple: Multinational Enterprises, International Trade,
and Productivity Growth, Firm-level Evidence from the United States; IMF
Working Paper WP/03/248, International Monetary Fund, Dec.2003; NBER Working
paper 9504, Feb.2003. Published 2009. Data from the International Investment
Division, U.S. Bureau of Economic Analysis (BEA). Have.
[KellerY:09]
Wolfgang
Keller and Stephen R. Yeaple: “Multinational Enterprises, International Trade,
and Productivity Growth, Firm-level Evidence from the United States”; The Review of
Economics and Statistics, MIT Press, Vol.91
no.4, pages 821-831. Data
from the International Investment Division, U.S. Bureau of Economic Analysis
(BEA). Published version of [KellerY:03]‡.
[Kemerer:93]†
Chris Kemerer: "Reliability of Function Points Measurement: A Field
Experiment"; Comm.
ACM, Vol.36 no.2, Feb.1993, pp.85-97.
: Garcetti v. Ceballos, 547 U.S. 410; Supreme Court of the United States, 2006. First Amendment free speech protections for government employees.
The plaintiff in the case was a district attorney who claimed that he had been passed up
for a promotion for criticizing the legitimacy of a warrant. The Court ruled, in a 5-4 decision,
that because his statements were made pursuant to his position as a public
employee, rather than as a private citizen, his speech had no First Amendment
protection.
[Kennedy:07] Justice
Anthony Kennedy: Microsoft Corp. v.
AT&T Corp.; Supreme Court of the United States 30 April 2007. Manufacturing CD
copies offshore from a Golden master disk supplied from the US does not
infringe US patent rights.
[KenneyD:05]
Martin Kenney and Rafiq Dossani: “Offshoring and the Future of U.S. Engineering:
an Overview”; The Bridge, National
Academy of Engineering, Fall 2005. Introduction to
related articles in the issue. Closing Article by William Wulf: “A Disturbing
Mosaic”.
[Kenny:11]
Charles Kenny: Small Isn’t beautiful; Bloomberg
Businessweek, 3 Oct.2011. Only a very small fraction of small businesses innovate and
grow. Based on [HurstP:11]
[KesslerE:06] Wolfgang
Kessler and Rolf Eicke: “Closer to Haven? New German Tax Planning
Opportunities; Tax Notes International, Vol.42 no.6,
8 May 2006. Dutch Sandwiches are called and illustrated as Hilversum 1 & 2.
[KesslerE:10] Wolfgang
Kessler and Rolf Eicke: “The New German GAAP – the Gap Between Commercial and
Tax Accounting”; Tax Notes International, Vol.59 no.7, 16 Aug),
2010. For more than 100 years the principle
of strict book-tax conformity (or the authoritative principle, or
Maβgeblichkeitsprinzip) ("§ 5 exp. 1 P. 2 EStG “) was the most
striking feature of German tax accounting. In fact, since the enactment of the
German Commercial Code (Handelsgesetzbuch, or HGB) on Jan.1, 1900, this
principle was a pillar that survived all storms of reforms until the last
reform, the Accounting Modernization Act (Bilanzmodernisierungsgesetz) went
into force on May 29, 2009.
[Ketsdever:10]‡ Nathan Ketsdever: The US should ablish
agricultural subsidies; IDEA discussion, 27 Aug.2010, <http://www.idebate.org/debatabase/topic_details.php?topicID=613.
On Kindle.
[Khadpe:01]
Subash Khadpe: Status of the Worldwide Packaging Foundry Industry; Chip Scale
Review, at <http://www.chipscalereview.com/issues/0501/f3_01.html> .
[Khimm:11] Suzy
Khimm: Bipartisanship lives! And it will likely cost taxpayers money; Ezra
Klein’s blog, Washingon Post, 5 Oct
2011.
[KimL:85]
Wi Saeng Kim and Esmeralda O. Lyn: “Excess Market Value, the Multinational
Corporation, and Tobin’s Q-Ratio”; Journal
of International Business Studies
Vol.17 no.1, Spring, 1986, Palgrave Macmillan Journals, pp.119-112:
[KimS:03]†
Sang-Hoon Kim and V. "Seenu" Srinivasan: A Multiattribute Model of the Timing of
Buyers’ Upgrading to Improved Versions of High Technology Products; Research
paper 1720R, Stanford Graduate School of Business, 2003.
[King:10] Eizabeth King: Transfer Pricing and Corporate Taxation:
Problems, Practical Implications and Proposed Solutions; Springer Verlag,
2010, 194pp. Have. Experience from private Practice. Cost-sharing loophole. Critique of CIP. eight case studies: 1.
diamonds, 2. medical devices, 3. R&D Services, disks, WD? 4. Internet
business model, 5 assets with embedded IP.
6 CDN services, Akamai, 7 global commodity trading, 8. Decentralized IP
ownership.
[KingEa:07] Steve King, Dan Burton, John Culberson, John Linder, Jeff Miller, Thomas Tancredo, and David Weldon: Proposing an
amendment to the Constitution of the United States to repeal the sixteenth
article of amendment; H.R. Resolution 16, 110th US
Congress, 17 Jan 2007,
<http://www.house.gov/list/press/ia05_king/pr_050202eliminateirs.html> ,
originally submitted 2 Feb.2005.
[KingL:93]
Robert G. King and Ross Levine: "Finance, entrepreneurship and growth: Theory and
evidence“; Journal
of Monetary Economics, Elsevier, Vol.32(3),
pp.513-542, December. 1993.
[Kirkegaard:04]
Jacob F. Kirkegaard: “Offshore Outsourcing – Much Ado About What”; CESifo Forum, a quarterly journal, Summer
2004, The IFO institute for Economic Research and, Munich, Germany, www.cesifo.de,
pp.22-29.
[Focus is on jobs, and corporate income, Globalization]
[Kirkpatrick:11]
David Kirkpatrick: Now Every Compnay is a Software Company; Forbes, 30 Nov.
2011.
[Klein:11a,b]
Ezra Klein: Herman Cain’s 9-9-9 plan in One Table; & The 9-9-9 plan in One
(very-long) graph; Washington Post,
18 & 19 Oct 2011.
[KleinK:01]
Kenneth Klein and Philip Karter: Transfer Pricing for Services; Chapter 44 in
[Feinschreiber:01] Transfer Pricing Handbook, 3rd Edition, Wiley, 2001. Here cost can be
used for value.
[Kleinbard:05]
Edward
Kleinbard: The Business Enterprise Tax [BEIT] ; presented to The President’s
Advisory Panel on Tax Reform, USC, May 2005.. business deductions for interest or dividends
paid equal to COCA. , annually included by investors. Reduce taxe to reduce
Evasion (slide42)
[Kleinbard:07]‡ Edward Kleinbard: Rehabilitating the
Busienss Income Tax; Brookings Institution, June 2007, 64pp. A business level consumption
tax proposal uses a Cost-of-capital-allowance to tac only non-routine
returns. No double taxation. Review of
current tax problems and evasion. Balance debt vs equity. Deals with
derivatives.
[Kleinbard:10]‡ Edward Kleinbard: “An American Dual
Income Tax: Nordic Precedents”; Nw. J.L.
& Soc. Pol’y, Vol.5, 2010, p.41.
[Kleinbard:12]‡ Edward Kleinbard: “Stateless Income”; Florida Tax Rev., Vol.9, 2011, p. 699. Cited by Sullivan. ..[ACM].
[Kleinbard:12C]‡ Edward Kleinbard: “The Sorry State of Capital
Income Taxation”;
NYU Colloquium in Tax Policy and Public Finance, 6 March 2012.
Discusses
Bain Capital 30% carried interest. Not for attribution. {VIC Ch10.8.2}
[Kleinbard:12R]‡
Edward Kleinbard: “Mitt Romney’s Marvelously Unburdened Income”: Huffington
Post, 27 Jan.2012. {VIC Ch10.9-G9}
[Klepper:96]
Steven Klepper: Entry, Exit, Growth, and Innovation over the Product Life
Cycle; The American Economic Review, Vol.86
no.3 (June , 1996), pp.562-583.
[Knoll:06] Michael S. Knoll: Taxes and
Competitiveness; Univ.
of Penn., Inst for Law & Econ Research Paper No.06-28,
14 Dec.2006. UBIT. Neutrality, not intangible
not offshore. Foreign real estate investment, no US laws can fix that. {VIC
Ch10.10.4}
[Knoll:07]
Michael S. Knoll: Business Taxes and International Competitiveness; paper 123, American Law
& Economics Association, Annual Meeting 2008, 6. UBIT.
Neutrality, not intangible , offshore.interest imbalance Foreign real estate investment, no US laws
can fix that. {VIC Ch10.10.4}
[..[ACM].
[Kocieniewski:11B] David Kocieniewski: “
[Kocieniewski:11G] David Kocieniewski:
“G.E.’s Strategies Let It Avoid Taxes Altogether”; The New York Times, 24 March, 2011. Corporate taxes
constituted 30 percent of all federal revenue in the mid-1950s. That rate had
fallen to 6.6 percent by 2009. 975 employees in tax department. Some
later corrections re state and future taxes. GE has $90B offshore. graphics. ..[ACM].
[Kocieniewski:11T]‡ David Kocieniewski: “Companies Push for Tax Break on Foreign Cash,” The New York Times, June 19, 2011. Repatriation. {VIC Ch7.6} ..[ACM].
[Kocieniewski:11V] David Kocieniewski: “Rich Tax Breaks Bolster Makers of Video Games”; The New York Times, 10
Sep.2011. Interaction
of R&E credits and taxhavens. Tax 98M, Profits 1.2B over 5 years, net loss
this year.<http://www.cfo.com/article.cfm/7292053?f=related>
..[ACM].
KohliD:04] R. Kohli and S. Devaraj: “Realizing the
Business Value of Information Technology Investments: An Organizational
Process”; Management Information Systems
Quarterly Executive (MISQE), Vol.3 no.1, March, 2004.
[Kogan:12] Richard Kogan:
What Was Actually in Bowles-Simpson — And How Can We Compare it With Other
Plans? ; CBP, 2 October 2012.
[KöllingS:02]
Arnd Kölling and Thorsten Schank: "Skill-biased technological change, international trade and the wage
structure“; 10th
International Conference on Panel Data, Berlin, July 5-6, 2002 B1-3,; Discussion
Papers 14,
Friedrich-Alexander-University Erlangen-Nuremberg, Chair of Labour and Regional
Economics.
[Kolm:03]
Petter Kolm: Trends in Quantitative Finance; 2006, <petter.kolm@gmail.com>
[Komag:01]
Komag PR: “Komag announces Voluntary Chapter 11 Bankruptcy Reorganization
Filing”, PRnewsWire, 24 Aug 2001. Komag goes POOF, but foreign subsidiaries are not
affected.
[Konczal:12]
Mike Konczal: An Interview With `Occupy The SEC’; The National Memo, 16 Feb
2012.
[KonvisserS:11]‡ Joshua Konvisser and Sanjeev Sachdeva: Indian
Outsourcing, End of the Offshore Tax `Vacation’?; Pillsbury Client alert, 7
March 2011.
[KopalleL:06]
Praveen K. Kopalle and Donald R. Lehmann: Setting Quality Expectations When
Entering a Market: What Should the Promise Be?; Marketing Science, Vol.25 no.1, January-Feb.2006, pp.8-24. (have abstract
only).
[Kopits:76] G. Kopits: “Intra-firm Royalties Crossing Frontiers
and Transfer-Pricing Behavior”; The
Economic Journal, Dec.1976, pp.791-803. Contractor 83: observes that the result
of royalty setting is affected by tax minimization strategies. {VIC AppC.2.4}
[Kornhauser:05]
Marjorie E. Kornhauser: “Doing the
Full Monty: Will Publicizing of Tax Information Increase Compliance?”; Can. J. L.& Juris., Vol.18, 2005,
p.95. {VIC Ch10.3.R8}
[Kornhauser:05C] Marjorie E.
Kornhauser: “Choosing a Tax Rate Structure in the Face of Disagreement”; UCLA Law Review, Vol.52 2005, pp.1697-1755. Progressivity as
finr, but redistribution is suspect. Congress should follow such an integrity
principle.
[Kornhauser:07] Marjorie E. Kornhauser: Normative and Cognitive Aspects of Tax
Compliance: Literature Review and Recommendations for the IRS Regarding
Individual Taxpayers; National Taxpayer Advocate, 2007 Annual Report to Congress
138, Vol.II,pp.138-180, <http://www.irs.gov/advocate/article/0,,id=177301,00.html>; also “A Tax Morale Approach to Compliance:
Recommendations for the IRS”; Fla. Tax Rev., Vol.8 No.6, 2007, p.599.
[Kovacs:05] László Kovács: Tax harmonisation
versus tax competition in Europe; Tax
harmonisation and legal uncertainty in Central and Eastern Europe; Austrian
Chamber of Professional Accountants and Tax Advisors, Vienna, Oct.20, 2005. The Author is the
European Commissioner for Taxation and Customs.
[Kovacs:06] László
Kovács: EU tax policy and its
implications for Ireland; European Commission, 2006, updated 10 Oct.2010. <http://ec.europa.eu/ireland/press_office/speeches-press_releases/kovacsspeech_en.htm.
10Oc 2010. Presentation in Ireland. The Author is the European Commissioner
for Taxation and Customs.
[KPMG:08]
KPMG International: KPMG's Corporate and Indirect Tax Rate Survey 2008; KPMG
International, Aug.2008. Covers most countries [KravitzB:05] Troy
Kravitz and Leonard E. Burman: Capital Gains Tax Rates, Stock Markets, and
Growth; Tax Facts, Tax Analysts ,
July 2005. On
JGTRRA . relate cap gains rate to S&P/GDP.
Correlation -.35 = weak negative. Realization ~3% of GDP.
[Kroll:06] Karen M. Kroll: “IRS seeks Truth in Veritas Deal”; CFO magazine, 20 Sep.2006. arbitrary,
capricious, or unreasonable’
[Kroon:00] Andries Kroon: The Netherlands and Netherlands Antilles in International
Tax Planning; in [Ogley:00] , pp.32-46.
[Krouse:12] Sarah
Krouse: “Budget day scramble for estate agents and lawyers”; Financial News, DowJones, 23 March 2012.
[KruchtenOS:06]†
P. Kruchten, H. Obbink, J. Stafford: "The Past,
Present, and Future for Software Architecture";
IEEE Software,
v. 23 no.2, pp.22- 30.
Harvard Business School Press, Nov.2009. Was on Kindle, now in references
[Krym:13]
Nick Krym: Outsource It! A No-Holds-Barred Look at the Good, the Bad,
and the Ugly of Offshoring Tech Projects; The Prgamtic Bookshlf, O’Reilly
Media, Feb. 2013.
[KueblerE:01]
D. Kuebler and W. Eibach: Metering and Accounting for Web Services, A dynamic
e-business solution: IBM Developer Works, 2001.
[KumraS:05]
Gautam Kumra and Jayant Sinha: "The next Hurdle for Indian IT"; McKinsey Quarterly, Issue 4 (Premium) 2003 Special Edition: Interview with Naranay Murthy (IIT
Kanpur MS 1969): Global directions and Infosys, <http://e.mckinseyquarterly.com/a/tBC2FwWAG8, have copy at
Outsourcing/EBSCOhost.pdfl>. Globalization.
[Kuittinen:12] Tero Kuittinen: “Missing the dazzling profit
potential of free apps”; BGR, 19 Nov. 2012,.http://bgr.com/2012/11/19/mobile-app-market-analysis-free-apps/.
from Sonny Chan CS207.
[KwiecinskiPH:06]
M. Kwiecinski, P. Peters, P., and D. Hoch: The
Overlooked Potential for
Outsourcing in Eastern Europe. The McKinsey Quarterly, 2006.
Globalization.
[KwonW:06]
, D. Kwon and S. Watts: “IT Valuation in Turbulent Times”; The Journal of Strategic Information Systems , 2006, Vol.15 no.4,
pp.327-354.
[Kyle:07]
Kyle: $300 Billion Tax Dollars Uncollected Last Year; Amateur
Asset Allocator, 2008 March 17, <http://amateurassetallocator.com/archives/. Good blog.
[Kynaston:01] David Kynaston: The
City of London, A Club No More, 1945-2000; Chatto & Windus, Randomhouse,
2001. Eurodollar market £1,010 in 1965 p.324. Eurobond $19016M 9n 1967.
[LafferM:10] Arthur B. Laffer and Stephen Moore: Return to Prosperity; Threshold Publications,
Simon & Schuster, 2010. Good governance
proposals in intro. Trade recommendations ignore IP. Proposes a flat tax in individuals and businesses
with few deductions, only labor. Fixed rate for corporations. Many data points,
not systematically organized. Have. [xls/taxes]
[LaMonica:05] Martin LaMonica: “Open source reshaping services
market”; CNET News, 10 Jan.2005.
[LandsbaumG:85]†
Jerome B. Landsbaum and Robert L. Glass: Measuring
and Motivating Maintenance Programmers; Prentice-Hall, 1985.
[Langbein:86]
Stanley I. Langbein: The Unitary Method and the Myth of Arm's Length; Tax Notes 625, 17 Feb.1986, Vol.30, 1986. Cited by Durst for
early arms length
[Larcker:04]†
David Larcker: in "Back to the Drawing Board: Is the Traditional Theory of the
Firm Obsolete?"; Strategic
Management, Wharton On-line report 1047, Sep.2004 <http://knowledge.wharton.upenn.edu/article/1047.cfm.
[Larson:11] Charles Larson: Panel Statement at National
Association for Business Economics 2011 Transfer Pricing Symposium in
Arlington, VA; Tax Analysts, 27 July
2011. Useful
life of IP. Limited life example is based on patents, not on trade secret.
[Laskey:00] Frederick A. Laskey: Letter Ruling 00-11: Massachusetts Tax Treatment of a Netherlands
BV, Department of Revenue, Commonwealth of Massachusetts; 29 Aug.2000.
[LathamS:05]‡
Robert Latham and Saskia Sassen (eds.): Digital
Formations: IT and New Architectures in the Global Realm; Princeton
University Press, 2005. t Columbia
University Dieter Ernst's essay on global flagship networks in Chapter 4 argues
that economic globalization has led to a type of international competition in
which multinationals create and maintain alliances of suppliers internationally
through digital information systems. The latter are used by global corporations
to diffuse certain types of knowledge "to gain quick access to skills and
capabilities at lower-cost overseas locations that complement the flagships'
core competencies" (p. 91).
This is a useful insight consistent with a growing number of empirical studies
of international collaborations in high-technology industries. My only
complaint is that it overly emphasizes the continued dominance of global firms
like IBM, Microsoft, and Intel at the expense of analysis of new corporate
challengers like Samsung in Korea or Acer in Taiwan or Lenovo and Haier in
China. The long-term consequences of short-term strategies of knowledge
diffusion need also to be considered.
[LauLW:05] Gloria T. Lau, Kincho H. Law, and Gio Wiederhold: ”Analyzing Government Regulations Using Structural and Domain Information” ; IEEE Computer, Vol.38 no.12, Dec.2005,
[Laurie:04] R. Laurie: “IP Valuation: Magic or Myth?”; in Intellectual Property Issues in M&A
Transactions, April 2004.
[Lawley:05] Duard Lawley: Common Sense Tax Reform; Authorhouse, 2005. Promotes a 1%: Universal Transaction Tax (UTT) to replace all taxes. Kindle.
[LB&I:10] IRS: Large Business and International Division
at-a-Glance; IRS, 1 Oct 2010, <http://www.irs.gov/irs/article/0,,id=96387,00.html>
[Lea:66]
Willard Harlon Lea: The ABCs of the Stock
Market; Vantage Press, 1966. Stanford Library checkout.
[Leamer:99] Edward E. Leamer: What do we
know About the Impact of Offshore Investment on the U.S. Economy?; in [Slemrod:99] . Recognizes the nonexclusivity of IP, but does not
follow up. Uses US export data, not offshore production, and focuses on FDI.
Lederberg:78] Joshua Lederberg: "Digital
Communications and the Conduct of Science: the New Literacy"; Proc.
IEEE., Vol.66 No.11, 1978. p.1314--1319.
[Lee:92]
Wm. Marshall Lee: "Determining Reasonable Royalty"; Les Nouvelles, Licensing Executives
Society , Vol.27 No.3, Sep.1992,
pp.124-128. See
Liberman:<http://www.youtube.com/watch?v=Ky4WNvHyaZw <http://www.lesi.org/Article/Les_Nouvelles_Online.html>. Cited in [FrankOW:09] : This rule of thumb is useful starting
place for negotiations; And [Parr:07] .
[Lefkowitz:05]† Robert Lefkowitz: Calculating the True
Price of Software; O'Reilly OnLamp.com, 21 July 2005.
[LeighFB:12]
David Leigh, Harold
Frayman, and James Ball: Offshore Secrets; The Guardian,
25 Nov.2012. 8 Articles: Sham taxhaven
directors, British Virgin Islands, UK government response.
[
[LeonardS:05]‡ Gregory
Leonard and Lauren Stiroh (eds.): Economic
Approaches to Intellectual Property Policy, Litigation, and Management;
National Economic Research Associates (NERA), White Plains, NY, 2005. (only few
citations regarding software) [have] rollover.
[Leonhardt:12]‡
David Leonhardt: “Coming Soon:`Taxmagedon’”; The New York Times, 15 April 2012.
Tax
bills to rise 1 Jan 2013 at all levels. Action will be needed, but will be
late.
[Leonnig :09]‡ Carol D. Leonnig: "Report Finds Major U.S. Companies Have Offshore
Tax Havens", “Bailed-Out
Firms Have Tax Havens, GAO Finds”;. Washington Post, 16 and 17 Jan. 2009. Shows some firms and amounts.
[LeontiadisPM:12] Ilias Leontiadis, Christos Efstratiou, Marco
Picone, and Cecilia Mascolo: “Don't kill my ads! Balancing privacy in an
adsupported mobile application market”; Proceedings of Mobile
Computing Systems & Applications Workshop, Feb. 2012. . from Sonny Chan CS207
[LenterSS:03] David
Lenter, Joel Slemrod, and Douglas Shakelford: “Public Disclosure of Corporate
Tax Return Information: Accounting, Economics, and Legal Perspectives”; National Tax Journal, March 2010,
pp.1733-1759. Specifics on what can be
disclosed. , ficis on schedules M-1 and m-2.Beranasek say dec 2003?
[Lentz:89] Karen
Panetta Lentz: "Hardware is
petrified software"; in Manoj Franklin: Computer
Architecture and Organization: From Software to Hardware; Prentice-Hall, 2010.
[Lepore:12]
Jill Lepore: “Tax Time, Why we pay”; The
New York Times, 26 Nov.2012, pp.24-29.
Box.
[LeRoyEa:12] Greg LeRoy, Phil Mattera, et
al.: Clawback, a Blog of God Jobs First; http://clawback.org/about/, Good Jobs First,
http://www.goodjobsfirst.org/. Specifics
about State incentives for corporations, tax expenditutres and subsidies,.
[Lessig:11] Lawrence
Lessig: Republic, Lost; Twelve,
Hachette, 2011.
[LeuzTW:06] Christian
Leuz, Alexander Triantis, and Tracy Wang: “Why Do Firms Go Dark? Causes and
Economic Consequences of Voluntary SEC Deregistrations”; American Finance Association, Boston, 2006. Authors at
UChicago. SoX effect or hiding trouble ? More hiding. <<find better
reference for Chapter 9, consolidated>>
[Lev:74] Baruch Lev: Financial Statement Analysis: A New Approach; Prentice-Hall, Inc.,
1974.
[Lev:99]
Baruch
Lev: “R&D and Capital Markets”; Journal of Applied Corporate Finance,
Winter 1999, pp.21-35.
[Lev:01] Baruch
Lev: Intangibles, Management, Measurement
and Reporting, with comments by conference participants; Brookings
Institution Press, 2001. Good reference for
problems. Proposes a `Value Chain Scoreboard' for intangibles. Inadequate
accounting for intangibles (p.7). Difficulty of using market cap (p.8).
Enormous cost of employees leaving to start competitors (p.13,35). Market
penetration (p.32). Trade secret importance (p.34). Includes an "Organizational
Capital" category (p.62-66). Customer acquisition (p.67). Workforce
(p.73-76). Write off of acquired R&D, but capitalization of software after
the point of technical feasibility (p.85-95). Have.
[LeveyEa:01]‡ Marc M.
Levey, Victor H. Miesel, William S. Garofalo, Michael F Patton, Kenneth J.
Krupsky, and Karl L. Kellar: Transfer Pricing: Alternative Practical
Strategies; Tax Management, BNA 2001.
[not cited]
[“’Commensurate with income’ … for intangibles” [p.6, 121] . ” Ownership [p.7] , Control [p.9] . Aribitrary, Capricuos, or ureasonable [p12] , DHL case, withholding documents [p.12, 110] , Formulary apportionment, multistate, global [p.14, 387] . Commensuratewith income [p.15] . BALRM with profit split [p.16] . Defer foreign payments [p.18] . Relationship to customs [p.24, 225] 40 countries now have transfer pricing rules [p.26] . Arm’s length [p.32, 149, 378] ., nearshor [p.63] . Disallowed repatriation [p.67] . Cost sharing [p.106,] . Services provided with IP [p.108] . Marketing intangibles, compustati [p.110, 118] . Buyout , difficulties in allocation, market valuations, goodwill, [p.129, p.139] . Market cap, purchase price [p.135] . p/e [p.137] . IRS uses TP method , IP life [p.138] . Stock options [p.151] . Section 361, 367 transfers [p.153] . temporary regs [p.156] . Loans, safe harbor [p.201] . penalties [p.209] . Statute of limitation [p.223] . Planning for exam, outside advisors, use of appeals [p.277] . IDRs [p.297] . R&D sources [p.303] , unusual patterns [p.303] . Embdeed sW [p.306] . High case loads and scrace resources interfere with the work of economists [p.307] . Strategic disadvantage in TP preparing a detailed rebuttal, may help the IRS [p.309] . Settlement [p.314] . limited communication between exam and appeals [p.315] . Stutute of limitation p245, the IRS attempts to understand the function and the risks of the business, and attempts to understand the effect of the intangibles on the transactions [p.304] . Keep the IRS examiner on track 305. If the IRS team were to misconceive the benefit contributed by an intangible 306. High case loads and scarce resources interfere with the work,mof IRS econmists. P307.
[
Have 2007 edition.
“Given the potential for
transfer pricing decisions to globally impact tax, financial and operational
results, it is unfortunate that relatively few persons at multi-national
corporations [MNEs] possess significant experience with transfer pricing
issues”;[p.v.] , “absent transfer pricing rules MNEs could intentionally or
unintentionally use transfer pricing to shift large amounts of income from one
tax jurisdiction to another.. that benefit could be used to reduce the MNE’s
overall tax rate” [p.2] , Shifting tax avoidance example as M&C [p.3] .
`double taxation’ computation <looks fair> [p.4] . “Tax payers may
report arms-length results on [a] income tax return that are different than the
results reported on their books” [p.5] “’Commensurate with income’ … for
intangibles” [p.6] . IRS cannot dictate business methofd [P.20] “Transfer of IP
occurs when … sold, assigned, loaned, or otherwise made available in any manner
[p.41] , if the terms include rights to exploit an intangible embedded within a
tangible, the price may have to be determined separately” [p.41-42] . [] ,
taxpayers hope to get away with low valuations by taking extreme positions
[p.83] . 3-year limit [p90] . Comtemporaneous
documnetaion [p.91] . IRS can intiate exam/aidit based on questionable result
[p.91] . Tisk of resolution [p.103] . Shortage of IRS economists [p114] .
Incentivev to move offshore [p.125] Reserve for uncertain tax obligations [p134]
. Simple compoarison of methods [p.141] Bought 19Jan 2009, Transfer Pricing Rules and Compliance Handbook [Paperback] , Price $91.49 Marc M. Levey; Steven C. Wrappe; and Kerwin Chung, Sold by: Amazon.com, LLC.
Bierce &
Kenerson
[LevinEa:11] Carl Levin et al.: Repatriating Offshore Funds: 2004 Tax Windfall for Select Multinationals; United States Senate Permanent Subcommittee on Investigations, 11 Oct.2011.
[Levin:12]
Carl Levin: Opening Statement; Permanent Subcommittee on Investigations, U.S. Congress, 20 Sep.2012. Microsoft
Singapore, Ireland, Hewlett Packard, $1.7T offshore. Short-term loan trick by
loaning from CFCs. to effectively repatriate. Section 206. 956 For the full hearing see. <http://www.hsgac.senate.gov/subcommittees/investigations/hearings/offshore-profit-shifting-and-the-us-tax-code>. [xls/forest] , [xls/taxhavens] ..[ACM].
[Levinson:08] Daniel
R. Levinson: Medicare Payment for
Irinotecan; Dept. of Health and Human Services, Office of the Inspector
general, OEI-03-08-00310. Aug.2008. (see also [Fein:08] .
[LevittLR:09] Steven D.
Levitt, John A. List, and David H, Reiley: What Happens in the Field Stays in
the Field: Exploring Whether Professionals Play Minimax in Laboratory
Experiments; presented at Columbia Univ, Oct 2012, July 2009.
[LevN:04] B. Lev and D. Nissim:
“Taxable Income, Future Earnings, and Equity Values”; The Accounting Review, Oct.2004 , 1039-1074; preview in The Economist, May 10, 2003,
p.57.
[LevS:96] Baruch Lev and
Theodore Sougiannis: "The Capitalization. Amortization, and Value-Relevance
of R&D"; Journal of Accounting
and Economics, 1996, pp.107-128. [in /guidance/references/LevSougiannis.pdfl>]
. From [LevS:96]‡
In 1985 the FASB made an exception to the full expensing requirement for some
software development costs, see FAS No.86 (Eccher, 1995). In several other
countries R&D capitalization is allowed and even required. For example, in
the UK, SSAP 13 requires that expenditures on pure and applied research should
be written off as incurred, but development expenditures may, in certain
defined circumstances, be deferred to future periods. The Canadian Standard
(section 345 of the CICA Handbook) goes further to require the deferment
of certain development expenditures. The International Accounting Standard, IAS
9, is generally in line with the Canadian standard with respect to R&D
capitalization.
[LevS:99] Baruch Lev and T. Sougiannis:
“Penetrating the Book-to-Market Black Box: The R&D Effect”; Journal of Business, Finance and Accounting,
April/May 1999, pp.419-449.
[Levy:01] Zion Levy:
Cost Sharing Arrangements; Chapter 9 in
[LeveyEa:01] ( Levey et al.: Tax
Management), pp.A-201 A-323. Contains the brief 1968 regulation on cost-sharing.
[Lewis:10] Michael Lewis: The Big
Short: Inside the Doomsday Machine; W.W.
Norton, 2010. Explains CDOs, FICO scores etc. Asks who Knew?
[Lewis:11] Michael Lewis: Boomerang: Travels in the New Third
World; [Kindle Edition] , 2011. Have on Kindle.
[LewisRR:11] Randall
A. Lewis, Justion M. Rao, and David H Reiley: Here, There,and Everywhere:
Correlated online Behaviors Can Lead to Overstimates of the Effects of
Advertising; WWW 2011, March 28–April 1, 2011, Hyderabad, India. ACM
978-1-4503-0632-4/11/03.
[LewisR:11] Randall A.
Lewis, Justion M. Rao, and David H Reiley: Does Retail Advertising Work? Measuring
the Effect of Advertising on SDaales via a Controlled Experimeny on Yahoo;
working paper 2011, presented at Columbia Univ, Oct 2012.
[LeymanR:00]† F. Leymann and D. Roller: Production
Workflow: Concepts and Techniques; Prentice-Hall, 2000.
LientzS:80]† B.P.
Lientz and E.B. Swanson: Software Maintenance Management;
Addison-Wesley, 1980. Longman Publishing Co., Inc.,
Boston, MA,
[LientzST:78] B. P. Lientz, E. B. Swanson, G. E. Tompkins:
Communications of the ACM, Vol.21 No.6, June 1978, pp 466-471.
[LII:92] Legal Information Institute:
Constitution, US code, Federal regulations, Supreme Court Cases, etc.; Cornell
Law School, since 1992 and continuously updated, <<http://www.law.cornell.edu/search/index.html>>.
[LII:92C]‡ Legal Information Institute: US code; in
[LLI:92] , for a US tax code section `§’ use <http://www.law.cornell.edu/uscode/text/26/§>.
[LII:92R]‡ Legal Information Institute: Federal
regulations; in [LLI:92] , for
regulations section `§’ in Part 1 use
<http://www.law.cornell.edu/cfr/text/26/1.§-0> for the first Section (-0).
[Lim:98]†
Wayne C. Lim: The Economics of Software Reuse; Prentice-Hall, 1998.
[Lindsay:09] Brink
Lindsay: Nostalgianomics; the Cato
Institute, 2009. <http://www.cato.org/pubs/wtpapers/Nostalgianomics.pdfl>. Critique of Paul
Krugman’s policies. “Often this phenomenon is discussed in terms of the growing
share of total income accounted for by the top 1 percent, or top 0.1 percent,
of earners. All of these statistics, though, are based on income tax data; and
income reported for tax purposes, especially by high-income taxpayers, is
extremely susceptible to changes in the tax code. Thus, analyses that track
incomes over decades and multiple major changes in tax policy are highly
problematic.17 Income gap increases due to excess supply of unskilled workers
and shortage of skilled workers.
[Linebaugh:12]
Kate Linebaugh: “Top U.S. Firms Are Cash-Rich Abroad, Cash-Poor at Home”; Wall Street Journal , 4 Dec.2012. Details on seceral
US companies. Does not explain source of foreign earnings.
[Linebaugh:13]
Kate Linebaugh: “Firms Keep Stockpil of `foreign’ Cash in the U.S.”; Wall Street Journal, 23 Jan..2013. As of 3Q2012.US companies hold e$1.7T a
being indefinitely invested overseas. Apple 68% of its $121.3B, Microsoft 87%
of its $66.6B, Qualcomm 63% of its $26.8B, Amgem 74% of its $25.4B; EMC $51B
out of 10.6, but 75 is invested in the US.Googl;e $29.1B. [ACM]
[LinebaughT:13]
Kate Linebaugh and Sharon Terlep: “Corporate News: Dell's Cash Overseas Is
Needed at Home --- Faltering Computer Business and Planned Buyout Put Demands
on Balance Sheet; But How to Avoid a Tax Bill?”; Wall Street Journal, 2
Jul..2013.
[Lipschutz:04]† Robert P. Lipschutz: A Better Blueprint for Business; PC Magazine, Sep.7, 2004.
[Litan:11]
Robert E. Litan: Startup
Businesses Key to Job Growth; @ Brookings Podcast #138, 18 Nov 2011. Startups, not
small businesses in general. Look at age.
[LocherB:02]
Peter
Locher and Ernst Blumenstein: System des Schweizerischen Steuerrechts, 6th.
ed.; Schulthess, 2002, ISBN 3-7255-4342-9.
Contains
rules for the Vereinsgesetz.
Lohman:02] Judith Lohman: Stanley Works Reincorporation Proposal;
OLR Research report, Office of Legislative Affairs, State of Connecticut, 002-R-063,
19 July 2002.
[Lohr:06] S. Lohr: Study
plays down export of computer jobs; The
New York Times, 23 Feb.2006. p.C11. Refers to ACM study
[Lojek:07] Bo Lojek: History
of Semiconductor Engineering; Springer Verlag, 2007. Relevant to VIC Ch
2.1. also see
Supporting Broad-Based Economic Growth and Fiscal Responsibility Through Tax Reform
[Lowry:08]‡ Reported by Reuters: Executive Refuses to
Answer Tax Haven Questions; The New York Times, Peter S. Lowry, 26
July 2008. Westfield
CEO , based in Liechtenstein at. LGT bank, loss $100 annually . Is 1/147 US
account holders. UBS has 190,000 US accounts. Covering $18B. Loss $100
annually. US has no subpoena powers,
[
Luce:07] Edward Luce: In Spite of the Gods, The Strange Rise of Modern India; Doubleday,
2007. 470M
workers, 35M pay income tax – work in a formal setting, 21M are civil servants,
14M private organized sector (POS); 1M in IT, 1-2M in foreign companies. 7M in Manufacturing. Productivity of
employees in POS was 6x in 1983, in 2000 9x employees in unorganized private
sector. Had.
[LundSS:11]
Mass Soldal Lund, Bjørnar Solhaug, Ketil
Stølen: Model-Driven Risk Analysis - The CORAS Approach; Springer 2011, XVI,
400 p.,
[Lynch:08] David J. Lynch: Does Tax Code send U.S.
jobs offshore; USA Today, 20 March 2008. <http://www.usatoday.com/money/perfi/taxes/2008-03-20-corporate-tax-offshoring_N.htm. Quotes Refers to Matthew Slaughter 2004 study, for
1991-2004 2 US jobs for every foreign job, later about equal 3.8M versus
3.6M. Does not understand IP and job
locale distinction.
[Maarsen:12] Hans Maarsen: Trustkantoren zien hun
positie bedreigd: FD 17 Sep 2012. Per Andre Nageklmaker, director of ANT. Competion for
Dutch CFIs from Cyprus. Annusal growth in Cyprus is 20,000; while Holland is
steady at 20,000, inclusing HP and Coca-Cola, 100 majors. In 2010 NL business was 10,000 billion (10.200 mrd)
euros.
[Mackay:1841] Charles Mackay: Extraordinary Popular
Delusions and The Madness of the Crowds; 1841, reprint Wiley, 1996. Invalidation of
Business patents
[MackEa:05] Connie Mack III, chair, et al.: Simple, Fair, and
Pro-Growth: Proposals to Fix America’s Tax System; Report of the President’s Advisory
Panel on Federal Tax Reform; Nov.2005. Also Two proposed plans, never
enacted. One is The Simplified Plan, the other. an extension, The Growth and
the Investment Taxplan. RRRR wrong. [xls/taxes]
[
[
[
[Madoff:10] Ray Madoff: Immortality and the Law: The rising Power of
the American Dead; Yale University Press, 1010. Estate taxes and trusts.
[Madoff:12] Ray Madoff: Two Tricks to Raising
Capital-Gains Taxes Fairly; The National Memo, 16 Feb 2012. the lower rates
cost the government a significant amount of revenue. In 2008, if capital gains
had been taxed at 35 percent instead of 15 percent, the federal treasury would
have received an additional $100 billion. (Capital gains were unusually low
that year; in 2007, the increase would have been closer to $200 billion.) In
the next five years, the capital- gains preference will cost the government
more than $450 billion, according to estimates from Congress’s Joint Committee
on Taxation. ... the special capital-gains rate makes it difficult to simplify
the tax code. Much of its complexity is due to the myriad rules that are meant
to ensure that income is properly categorized as ordinary income or capital
gains. Eliminate the rate differential, and the tax code could become far less
complex. Fix for gains due to inflation (mainly real estate) up to death. Thus,
if a taxpayer invested $100,000 in Apple Inc. in 2006 and died in 2012 when the
stock was worth $1 million, that $900,000 profit is never subject to tax. The
decedent is not taxed because he didn’t sell the stock, and the heirs are not
taxed because they are treated as if they had purchased it for $1 million. Even
at 15 percent capital-gains rates, this angel of death loophole costs the
federal government about $60 billion each year. It also creates a powerful
incentive for people to hold on to their appreciated property until death. This
so-called lock- in effect impedes the efficient flow of capital. {ACM]
[Magrassi:85?] Paolo Magrassi: A Taxonomy of Intellectual
Capital, Stamford: Gartner. 18 July 2002?. Gartner Research Note COM‑17‑1985. He also published several
books in Italian, including Digitalmente confusi (2011), La
good-enough society (2010), Difendersi dalla complessità (2009), Il
filo conduttore (2006), 2015 Weekend nel futuro (2005).
[Magrassi:02] Paolo Magrassi: A Taxonomy of Intellectual
Capital, Stamford: Gartner. 18 July 2002?. Gartner Research Note COM‑17‑1985. Cites Sveiby. He also published
several books in Italian, including Digitalmente confusi (2011), La
good-enough society (2010), Difendersi dalla complessità (2009), Il
filo conduttore (2006), 2015 Weekend nel futuro (2005).
[MahajanMW:00]† Vijay Mahajan, Eitan Muller, and Yoram
Wind (eds.): New-Product Diffusion Models; International Series in
Quantitative Marketing, Kluwer, 2000.
[Mahoney:92] Joseph T. Mahoney: “The Choice of Organizational Form: Vertical Financial Ownership
Versus Other Methods of Vertical Integration; Strategic Management Journal,
Vol.13 No.8, Nov.1992, pp.559-584.
[Makhlouf:02] Gabriel Makhlouf: List
of Uncooperative Tax Havens; Committee on Fiscal Affairs, OECD, Paris, France, April 19, 2002. List has been removed from the OECD web
page.
[Malm:13] Elisabeth Malm: Colorado Aamndement
66: A $1 Billion Tax Increase on Small Business and Individual Taxpayers; The
Tax Foundation, 17 Oct.2013. The tax is to benefit education – how
is that measured?
[MalmK:13]‡ Elisabeth Malm and Ellen Kany:
The Sources of State and local revenues; The Tax Foundation, 29 Jan.2013.
[Malthus:26] Thomas Robert
Malthus: An Essay on the Principle of Population: A View of its
Past and Present Effects on Human Happiness; with an Inquiry into Our Prospects
Respecting the Future Removal or Mitigation of the Evils which It Occasions (Sixth ed.); John Murray, 1826. <http://www.econlib.org/library/Malthus/malPlong.html>. Retrieved
2008-11-22.
[Mandel:09]‡
Mike Mandel: The GDP Mirage: the failure to
account for IP generation makes predictions of growth suspect; Business Week, 9 Nov.2009,
pp.35-38. Offshore R&D is counted, but does
not generate US GDP. Chap.9
[ManesA:94]†
Stephen Manes and Paul Andrews: Gates; Simon and Schuster, 1994.
[Manesh:12] Mohsen Manesh: “Contractual Freedom under Delaware
Alternative Entity Law: Evidence from Publicly Traded LPs and LLCs”; University
of Oregon School of Law, to appear in Journal
of Corporation Law, 2012.
[ManishS:08]
Shashank Manish and Arun Soni: ‘Tax havens and money laundering in India’; Gujarat
National Law Univ., undated..
[MankiwW:05] N. Gregory Mankiw and Matthew Weinzierl: Dynamic Scoring: A Back-of-the Envelope Guide; Harvard University, 12 Dec.2005. Estimating Effect of tax cuts. Less than Laffer, more than static – about 31% for financial capital, 16% for labor. Based on balance of capital and labor. But for high tech industries little capital is involved.
[Mankiw:12] H. Gregory Mankiw: A better Tax System (Instructions
Included); The New York Times,
Economic View, 22 Jan.2012. 4 principles:
Broaden the base and lower the rates (no mortgage deduction); Tax Consumption
rather than income; (IRAs do); Tax `Bads’
rather than goods (tax gas at $2); Keep it simple (avoid loopholes as: electric
car deduction used for golf carts).
[Manoogian;12] John Manoogian III: “How free apps can make more
money than paid apss”; Techcrunch, 26 Aug. 2012, http://techcrunch.com/2012/08/26/how-free-apps-can-make-more-money-than-paid-apps/.
. from Sonny Chan CS207
[MarceauMW:06]
Nicolas Marceau, Steve Mongrain, and John D. Wilson.: “On the Efficiency of Tax
Havens”; Mimeo, Michigan State University, 2006.
[Marcus:04]‡
Rosemary Marcuss, “Corporate Profits in the GDP Accounts,” Bureau of Economic
Analysis, Presentation at Conference for National Association of Business Economics,
Kissimmee, Florida, May 2004, http://www.bea.gov/papers/pdf/nabeprofits_fv.pdf. Corporate Surplus
(OECD term) versus Corporate Profit.
[Maremont:12]
Mark Maremont: Romney IRA’s Offshore Investments: Helping His Tax bill; The Wall Street Journal, 19 Jan.2012.
Refers to [MoskRC:12]
[Marisec:06] Marisec: International Shipping, Carrier of World Trade; Maritime
International Secretariat Services Ltd,
London, 2006, <http://www.marisec.org/worldtradeflyer.pdfl>; container shipping costs.[xls/ports]
[Marisec:10] Marisec: Shipping and
World Trade; Maritime International Secretariat Services Ltd, London, 2010. <http://www.marisec.org/top-20-largest-shipping-flags.php.htm.
[xls/taxhavens]
[Markham:05] Michelle
Markham (Bond University): The Transfer pricing of intangibles; Wolters-Kluwer,
2005. Focus
on international consistency / harmonization. Have.
[MarkleS:09] Kevin S. Markle and
Douglas A. Shakelford: Do Multinationals or Domestic Firms Face higher
Effective Tax Rates; University of North Carolina Univ., June 2009. Many details on
effective tax rates. US 28%. Sweden and Taiwan Southafrica 25% 18% France 23% Including taxhaven effects,
local and for multinationals. Consistent
with U.S. multinationals’ exploiting their ability to report profits in
locations with more favorable tax systems than the U.S., the foreign affiliates
of American companies reported more of their aggregate net income in the
Netherlands (13%), Luxembourg (8%), and Bermuda (8%) than any country in 2006 (<http://www.bea.gov/international/di1usdop.htm).
Other locations with profits that far exceeded assets, sales and employees were
Ireland (7%), Switzerland (6%), Singapore (4%), and UK islands in the Caribbean
(3%). For comparison, 7% of the aggregate net income of U.S. foreign affiliates
was reported to Canada (the U.S. largest trading partner) and the UK, while
only 2% was reported in Japan and Germany, which are considered among the most
highly-taxed countries. (Chap.9)
[Marr:11]
Chuck Marr: Corporate Tax Holiday has No Place on Payroll Tax-Cut Extension
Bill; Center on Budget and Policy Priorities, 8 Dec.2011. Discusses CBO
graph on Tax repatriation for Job Creation.
[MarrH:11] Chuck Marr and Brian Highsmith: Tax Holiday for Overseas Corporate Profits
would Increase Deficits, Fail to Boost the Econmy, and Ultimately Shift More
Investment and Jobs IOverseas; Center on Budget and Policy Priorities, 23 June
2011. Discusses
job losses.
[Martin:05] Patrick W. Martin: “Oops – The
Accidental Inversion”; Procopio, 24 Apr.2005. “The Service will undoubtedly be
frustrated in its efforts to enforce the U.S. tax law vis-à-vis the foreign
parent corporations in foreign jurisdictions (especially in those countries
without any U.S. income tax treaty) when there is no nexus to the U.S. other
than the U.S. shareholdings of foreign parent corporation.”
[Martin:09] Roger L. Martin: Design of
Business, Why Design Thinking is the Next Competitive Advantage, 3rd
ed.; Harvard Business School Press, 2009.
[Martin:11] Roger L. Martin: Fixing
the game; Harvard Business Review Press, 2011. On Kindle. 1. repeal of 1995 Private Securities Litigation
Reform Act, which contains what has become known as the “safe harbor”
provision. 2. elimination of regulation
FASB 142 which forces the real write-downs of real assets based on the
company’s share price in the expectations market. 3. eliminating the use of stock-based compensation as an incentive.
4. restore authenticity to the
lives of our executives. 5.
board governance.5. regulate
expectations market players, most notably hedge funds. Net, hedge funds
create no value for society. They have huge incentives to promote volatility in
the expectations market, which is dangerous for us but lucrative for them. Have
on Kindle.
[Martin:13A]
Julie Martin: Amazon fighting IRS over cost-sharing Buy-in payment; Tax Notes Today, 15 Jan 2013. $1B at stake.
Amazon refers to Verita,
[Martin:13B] Julie Martin: Maruca Outlines IRS
Approach to Transfer Pricing; Tax Notes
Today, 19 Feb. 2013. Do not accept taxpayer results that are too good to be true.
[MartinsSP:96] Joaquim Oliveira Martins, Stefano Scarpetta ,and Dirk
Pilat: "Mark-Up Ratios in Manufacturing Industries: Estimates
for 14 OECD Countries“; OECD
Economics Department Working Papers
162, , 1996, OECD Publishing. [Downloadable!]
[Maraia:05]†
Vincent Maraia: The Build Master: Microsoft's Software Configuration Management
Best Practices; Addison-Wesley Microsoft Technology, 2005.
[Marciniak:94]†
John J. Marcianak: Encyclopedia of Software Engineering; Wiley, 1994.
[MarksM:10] Mitchell
Lee Marks and Philip H. Mirvis: Joining Forces: Making One Plus One Equal Three in Mergers, Acquisitions,
and Alliances,
Revised and Updated; Jossey-Bass, Wiley, July 2010.
[Markusen:90]
James R. Markusen: First Mover Advantages, Blockaded Entry, And the
Economics of Uneven Development; NBER
Working Paper No.3284*
Issued in March 1990. RB case.
[Marlow:78]
Marlow, Richard: “Matrix Approach to Pricing”; Les Nouvelles, March 1978,
p.11. Method based on Nabisco license
estimation.
[MartinsonEM:99]
O.B. Martinson, T.D. Englebrecht, and C. Mitchell: "How multinational
firms can profit from sophisticated transfer pricing strategies"; Journal of Corporate Accounting &
Finance, Vol.10 no.2, 1999, pp.91-103.
[Marx:1867]
Karl Marx: Das Kapital; 1867. On Kindle
[Mathur:12]‡ Aparna Mathur: How Taxing the Rich
Harms the Middle Class; The American,
the Online magazine of AEI, 15 Feb.2012.
[MathurK:10] Aparna
Mathur and Kevin Hassett, AEI., same as [HassettM:10] .
[Matsunaga:83] Yoshio Matsunaga: Determining reasonable royalty rates”; Les Nouvelles, Journal
of the Licensing Executives Society, Dec.1983, pp.216–219.
(App.G)
[MatternSS:03]‡ Frank Mattern, Stephan Schönwälder, and Wolfram Stein: "Fighting Complexity in IT"; McKinsey Quarterly, April 2003.
[Matthews:06] Dylan:
Matthews: In-House Critic Holds IRS Feet to the Fire; Wall Street Journal, 2006. $2T collected, 130M individual, 25M corporate
taxapyers Tax gap $290B.0 . Confused
with Robert Guy Matthews on data disclosure.
[Matthews:10] Dylan
Matthews: The corporate tax
shuffle ; Washington Post, 6 April 2010. Comments on [Hellman:10]
[MauboussinJ:97]
Michael Mauboussin and Paul Johnson: “Competitive Advantage Period”: The
Neglected Value Driver”; Financial Management, Vol.6 No.2,
Sum.1997. Life of non-routine returns.
[MauldinA:08] Tiffany Mauldin and Edward Abahoonie: More likely than
not: A comparison of FIN 48 and the tax penalty standard; The Tax Executive, March 2008;
Price
Waterhouse Coopers (PWC), 2008.
[Mauer:04]
Hermann Maurer: Das ParaNetz; Der Zusammenbruch des Internets; Freya Pub.,
Austria, 2004; English translation: The ParaNet (breakdown of the Internet);
booklocker.com, 2004. Science Fiction attacks Globalization.
[Maxton:11] Graeme Maxton: The End of Progress; How
Modern Economics Has Failed us; Wiley, 2011.
Growth,
responsibility, economic rape.
[MaydewS:05]
Edward L. Maydew and Douglas A.
Shackelford: The Changing Role of
Auditors in Corporate Tax Planning; University of North Carolina and NBER,
WP2005-10, June 2005. Fee data, many good references
[Mayshar:91]
Joram Mayshar: “Taxation with Costly Administration”; Scandinavian
Journal of Economics, Vol.93 no.1 1991.,
pp 75-88.
[Mazarov:12] Michael
Mazarov: `Digital Goods and Services Fairness Act’ Would Impair Funding for
Education, Health care, and Other Stte and Local Services; Center for Budget
and Policy Priorities. 29 May 2012.
[Mazza:03] S Mazza: The Interplay Between Norms and Enforcement in Tax
Compliance ...; . Mar 28, 2003
–ssrn.com/sol3/papers.cfm?abstract_id=391133.
A
number of scholars have suggested that vigorous enforcement of the tax laws may
be counterproductive because it may suggest that ... (Chap.8)
[MazzolariR:07]
Francesca Mazzolari and Giuseppe Ragusa, 2007. "Spillovers from High-Skill Consumption to Low-Skill
Labor Markets“; IZA
Discussion Papers 3048, Institute for
the Study of Labor (IZA) and UC Irvine. Wage inequality,
increase in US service jobs. US focus, data.
[McAfee:83] R.Preston
McAfee: “American Economic Growth and the Voyage of Columbus”; American Economic Review, Vol.73, 1983. The misuse of
hypotheticals or counterfactuals: “If the world were flat, Columbus would certainly not have
observed masts rising over the horizon as ships came in. As a result, he would
have not believed the earth to be round, and would never have sailed. Hence he
could not have fallen off the edge”.
[McAfeeL:09] R.Preston McAfee and
Tracy R.
[McBride:11]‡
William McBride: "Beyond the Headlines: What Do Corporations Pay in Income
Tax?"; Tax Foundation Special Report No.194, Sep.2011. Foreign taxes
explain most of the difference beween statutory and effective tax rates. In
2008 the 1,937 largest cos paid 68% of
corp tax revenues. If taxes on foreign income are included the effective rate
becomes 32.1 to 32%. Not used.
[McBride:13N]
William McBride: "New Zealand’s experience with Territorial Taxation";
Tax Foundation, 19 Jun. 2013. ";
Tax Foundation, 19 Jun. 2013. see [GAO:13],
flaws indicated, but no fix
[McBride:13O]
William McBride: " GAO Compares Apples to Oranges to Find Low Corporate
Effective Tax Rate"; Tax Foundation,
3 Jul. 2013. [ACM}
[McBride:13T]
William McBride: " A brief History of Tax expenditures"; Tax
Foundation, 22 Aug. 2013. Considers
coirporate taxation a reverse Tax expenditures , because of doubl taxation.
Other corporate Tax expenditures are modest.
[McCabe:09]
Cynthia Kopkowski McCabe: Education
Funding, Follow theMoney; National Education Association, Feb.2009.
[McCarthy:zz] John
McCarthy: It is a folly to think that things can be improved by forbidding
something”
[McCloskey:97]
Deirdre N. McCloskey: “The Good Old Coase Theorem and the Good Old Chicago
School, a comment on Zerbe and Medema”; in Medema (ed), Coasean Economics, Kluwer, 1997, pp.239-248. Transaction costs
versus Pareto Optimality when participants are independent.
[
[McGee:12] Robert W. McGee (ed.): The Ethics of Tax Evasion, Perspectives in Theory and Practice; Springer, 2012, 704pp. Little on corporate tax evasion. From Springer site: Why do people evade paying taxes? This is the central question addressed in this volume by Robert McGee and a multidisciplinary group of contributors from around the world. Applying insights from economics, public finance, political science, law, philosophy, theology and sociology, the authors consider the complex motivations for not paying taxes and the conditions under which this behavior might be rationalized. Applying theoretical approaches as well as empirical research, The Ethics of Tax Evasion considers three general arguments for tax evasion: (1) in cases where the government is corrupt or engaged in human rights abuses; (2) where citizens claim inability to pay, unfairness in the tax system, paying for things that do not benefit the taxpayer, excessively high tax rates, or where taxes are used to support an unpopular war; and (3) through philosophical, moral, or religious opposition. The authors further explore these issues by asking whether attitudes toward tax evasion differ by country or other demographic variables such as gender, age, ethnicity, income level, marital status, education or religion. The result is a multi-faceted analysis of tax evasion in cultural and institutional context, and, more generally, a study in ethical dilemmas and rational decision making.
; Citizens for
Tax Justice, 1 Oct.2012. capital gain. Data based on Institue on Taxation and
economic Policy.
[McKendrickDH:00]
David McKendrick, Richard Doner, and Stephen Haggard: From
Silicon Valley to Singapore, Location and Competitive Advantage in the Hard
Disk Industry; 2000. on Kindle.
[McKenney:12]‡
Michael E. McKenney: Final Audit Report ROTER; TIGTA, 7 Aug.2012 <http://www.tigta.gov>.
[McKinnon:11]
John D .McKinnon: Rep. Camp Unveils Business-Friendly Corporate Tax Plan;
Washington Wire, Wall Street Journal
Capital Bureau, 26 Oct 2011. also Camp11,HR. Ways and Means Discussion Draft, 26
Oct.2011.
[McKinsey:03] McKinsey: "Fighting Complexity in IT"; McKinsey Quarterly, April 2003.
[McMillan:03]
John McMillan: Reinventing the
Bazaar: A Natural History of Markets; WW Norton, 2003.
Red Hat users balk at Enterprise Linux licensing;
[McLeanN:11]
Bethany McLean and Joe Nocera: All the
Devils are Here; Portofolio,
20111. About the financial crisis, CDO’s,
Solid history, politically neutral. Countrywide CEO Angelo Mozillo.
[McNair:03] Carol J. McNair: The
Profit Potential: Taking High Performance to the Bottom Line; Wiley, 2003. Forgone profit is
the opportunity cost of delay = days excess delay x daily Vol.planned x expected profit .
[Medema:97]
Steven G. Medema (Associate Professor of Economics, University of Colorado at
Denver) and Richard O. Zerbe, Jr (University of Washington, Graduate School of
Public affairs): The Coase Theorem; in Medema (ed), Coasean Economics, Kluwer, 1997, pp.209-238. “the British
Tradition”.
[MeekerW:13] Mary Meeker and Liang Wu: Internet Trends
D11 Conference; presenation, Kleiner Perkins Caulfield Byers, 29 May 2013, http://www.slideshare.net/kleinerperkins/kpcb-internet-trends-2013?utm_source=slideshow&utm_medium=ssemail&utm_campaign=weekly_digest>. Excellent presenation of the many
convoluting factors in growth of the Internet and its use.
[MegnaM:91] Pamela Megna and Dennis C. Mueller:
"Profit Rates and Intangible Capital”; Review of Economics and
Statistics, 1991.
[MehtaF:11] Aaron Mehta and John Aloysius Farrell: Wealthy Corporations with a Trillion Dollars
Stashed Offshore Lobby for a ‘Holiday’ from U.S. Taxes; Nation of Change, 24 Oct 2011.
[Meinzer:09]‡ Marcus Meinzer: Number of Companies; Mapping the Fault Lines, Tax Justice
Network, 2009, <http://www.secrecyjurisdictions.com/PDFL>/NumberCompanies.pdfl>.
[MeldmanS:00] Robert Meldman and Michael S. Schadewald: Practical Guide to U.S.
Taxation of International Transactions (Sixth Edition); CCI, 2000.
[MellahiJ:00] Kamel Mellahi and Michael Johnson: “Does
it pay to be a first mover in e.commerce? The case of Amazon”; Managment Decision, Vol.38 no.7,
pp.445-452. MCB University Press, now Emerald Press UK, July 2000.
[MelnikB:06]‡ Steven V. Melnik and Bernard Baruch:
Corporate Inversion Strategies; American Institute of CPAs, 14 July 2006.
[MergesML:06] Robert P. Merges, Peter S. Menell, Mark
A. Lemley: Intellectual Property in the Technological Age, 3rd ed.; Aspen,
2006. Have (Case studies, incl. International). prior editions 2003,
1997. I have
also 2005 Case and Statutory Supplement.
Software chapter 7 focuses on protection. Versions substitute. Trade
secrets dominate (p.995+). Nothing on Life.
[MetropolisW:80] Nicholas Metropolis and J. Worlton:
"A Trilogy on Errors in the History of Computing"; Annals of the
History of Computing, Vol.2 No.1, Jan.1980, pp.49–55. Replaced by Dyson
[Michael:13] Gabriel J. Michael: Anarchy and Property
Rights in the Virtual World: How Disruptive Technologies Undermine the State
and Ensure that the Virtual World Remains a 'Wild West'; SSRN 2233374, 1 Mar.2013. Focus on entertainment IP, impossibility
to enforce regulations. {VIC Ch3.1}
[Michaelsen:93] Ulrik
Fleischer-Michaelsen: “Denmark's Transfer Pricing System is Attractive to
Foreign Corporations”; J. INT'L TAX'N
; Vol.226, May 1993. {VIC Ch..6.4}
[Michie:92]
Ranald C. Michie: The City of London;
Basingstoke, 1992.
{VIC
Ch..6.6}
[MeyerK:04] David Meyer and Martin Kenny:
“Economic action does not take place in a vacuum: Understanding Cisco’s
acquisition and development strategy”; Journal
of industry and Innovation, Dec.2004.
[Mihaly:93] S. Mihaly: “United States: How to Escape the Wrath of
Thrasbulus’ Sword and Establish Reasonable Royalty Rates in Intercompany
Licensing of Intangibles Under the `Best Method Rule’of the New Section 482
Regulations; Bulletin for International
Fiscal Documentation, Vol.47 No.309, June 1993.
[Miles:05] Miles: ‘‘Intermediary Dutch Holding Company Qualifies for
Parent/Subsidiary Directive Relief’’; Tax
PlanningInternational Review, Vol.32, 2005, pp.16, 17. {VIC Ch..6.3}
[MillerVC:10] Keith W. Miller, Jeffrey Voas, and Tom
Costello: “Free and Open Source Software”; IT
Professional, IEEE , Nov.2010, p.14-17. {VIC
Ch..3.3.4}
[MinittiPS:08]
A. Minniti, C.P. Parello, and P.S. Segerstrom: "A Schumpeterian Growth Model with
Heterogenous Firms“; Working
Papers 645, Dipartimento Scienze
Economiche, Universita' di Bologna; MPRA
Paper 13674, University Library of
Munich, Germany, 2008. R&D success is highly skewed, long tail of high profits.
Parameters for subsidy decisions. {VIC Ch8.7}
[Milsted:12]
Carl Milsted jr.: The Limits to the
Laffer Curve, National Debt Solutions, 2012, <http://www.nationaldebtsolutions.org/
{VIC Ch10.7}
[Misey:02] Robert J. Misey, jr.: “An
International Tax Review: The U.S.-Based Multinationals, Annual Checkup”; Taxes, the Tax Magaziune, CCH Inc, Dec.2002. Subpart F. ETI, filing requirements for CFCs.
[Misey:99] Robert J. Misey, jr.: A primer on Tranfer
Pricing; Tranfer Pricing for Dummies/ www.interlaw.org
www.interlaw.org/newsite/Pubs/Docs/tpart.doc
[MiseyS:07] Robert J. Misey jr. and Michael S. Schadewald: Practical Guide to U.S. Taxation of International Transactions, 6th ed; CCH Wolters-Kluwer, 2007.
have.
[Mishan:67] E. J.
Mishan: “Pareto Optimality and the Law”; Oxf. Econ. Pap. (1967) 19(3):
255-287.
[MishelS:12] Lawrence Mishel and Natalie
Sabadish: CEO pay and the top 1% How executive compensation and
financial-sector pay have fueled income inequality; Economic Policy Institute, 2 May 2012, in The State of Working America, 12th edition, Sep. 2012.
[Mitchell:10F] Dan
Michell: Choosing the Flat Tax over the Fasir Tax; Center for Freedom and
Prosperity, 18 Aug.2010. Junbk the
IRS. Repeal the 16th
amendment. Fair tax requirrs trusting
politicians. Vidoe on European adpotioon of the VAT.
[Mitchell:10L] Dan
Michell: What is Ideal Point on the Laffer Curve; Center for Freedom and
Prosperity, 18 Aug.2010. Does not trust JCT
estimates. Supports Mankiw,
Feldstein. Has 3 videos attached.
[Mitchell:11] Rick Mitchell: At G-20, Sarkozy names Switzerland,
Liechtenstein among 11 Tax havens; BNA Daily Tax Report; 7 Nov.2011.
[Miyatake:09] Toshia
Miyatake: Japan’s Foreign Subsidiaries’ Dividend Exclusion; Proceedings from
the 2009 Sho Sato Conference on tax Law, Social Policy, and the Economy, March
2009. By moving to full deductabilty of dividends for
corporate profits, territorial taxation becomes closer. But taxhavens can stll
be addressed.
[MoellerLK:09]‡ Volatility in leverages. Replaced by {Wilson:11]‡.
[Moody:09] Glynn Moody, Rebel
Code: Linux and the Open Source Revolution; Basic Books, 2009. Covers many
project,, large and small. on Kindle [ACM].
[MoodyWH:05] J. Scott Moody, Wendy P. Warcholik &
Scott A. Hodge: Special Report: The Rising Cost of Complying with
the Federal Income Tax; Tax
Foundation, Dec. 2005, http://www.taxfoundation.org/research/show/1281.html>
[Mookerjee:05]†
Radha Mookerjee: "Maintaining Enterprise Software Applications";
Comm. ACM, Vol.48 no.11, Nov.2005.
Testimony Before the Committee on Ways and Means”;
Joint Committee on Taxation (JCT), 22 July 2010. Author is with Horst Frisch,
Inc. Income shifting by one company forces others to follow. Need for IP valuation.
Veritas was a bad deal for US shareholders.
[MorgensonR:11] Gretchen Morgenson and Joshua Rosner: Reckless Endangerment: How Outsized
Ambition, Greed, and Corruption Led to Economic Armageddon; Times books, May 2011. Legislation and Regulation. Trust Preferred Securities
Mortgage lenders. Focus on FannieMae [Morgenthau:09] Robert M.
Morgenthau: Cayman Islands hold $1, 900B; Charlie Rose Interview, 8 April
2009. D.A. NY 1975 year2009 (Son of Henry M.
Treasury Sec. 1934-1945?.
[Moore:95]† Geoffrey A. Moore: Inside the Tornado: Marketing Strategies from
Silicon Valley's Cutting Edge; Harper
Business, 1995.
[Moore:12]‡
Jack Moore: 2012 budget ups IRS funding; Federal News Radio, 20 August 2012. [xls/irs]
[Moorehead:84]
Donald V. Moorehead: Selected Current Developments in Subchapter C; William and
mary Annual Tax Confrence, paper 547, 1984. Tainted assets are subject to a
stauutory toll charge, i.e. erxport taxation..
[
[Mortished:06]
C. Mortished: "GSK settles largest tax dispute in history for $3.1B";
Times Online 12 09.2006. Business. 16 09.2006
<http://business.timesonline.co.uk/article/0,,13129-2353321,00.html>.
[Mortished:09]
Carl Mortished: "Tax haven report lays emphasis on vital role of
Crown Dependencies"; The Times of
London, 30 Oct. 2009..
[MoskRC:12] Matthew Mosk, Brian Ross, and Megan Chuchmach: Romney
Parks Millions in Cayman Islands; ABC
News Nightline, 18 Jan.2012. Has 138 funds.
[MS:11] M.S.:
“Foreign Aid, Why Ron Paul is Wrong”; The
Economist, 16 Nov. 2100.
[MulfordR:06]
Charles W. Mulford and Jack Roberts: Capitalization of Software Development
Costs: A Survey of Accounting Practices
in the Software Industry; College of
Management, Financial Analysis Lab., Georgia Tech., May, 2006. Only 61/207 of
companies actually capitalized SW, at a mean rate of 20%.
[Mulally:11] Alan Mulally
(CEO of Ford): `70 % of R&D is
associated with manufacturing’; conversation with Charlie Rose; Bloomberg
Businessweek, 1 Aug.2011.
[Mulligan:09] Mark Mulligan: “Spotify: why it’s been so successful
and what it needs to do”; Music Industry Blog,
6 Feb. 2009, http://musicindustryblog.wordpress.com/2009/02/06/spotify-why-it's-been-so-successful-and-what-it-needs-to-do-next.
. from Sonny Chan CS207
[Mulligan:12] Casey B. Mulligan: Will the I.R.S. be
busy next Year?; The New York Times, 1 Feb.2012. Differences in audit rates under democratic versus
Republican administrations.
[Mundstock:87]
George Mundstock: Taxation of Business Intangible Capital; 135 U. Pa. L. Rev.
1179 (1986-1987)
[Murphy:12] Richard Murphy: The Courageous State, Rethinking Economics,
Society, and the Role of Goverment; 2012.
[Murphy:09] Richard Murphy: The language of
Tax; Mapping the Fault Lines, Tax
Justice Network, Nov.2009, <http://www.secrecyjurisdictions.com/PDFL>/Glossary.pdfl>.
[MurphyCK:05]
Richard
Murphy, John Christenson, and Jenny Kimmis: Tax us if you can; Tax Justice
Network, Sep.2005, 78pp.Capital Flight, HNWIs . List of Taxahavens
[Murthy:11] N.R. Narayana Murthy: Infosys Annual report;
2010-2011, Infosys corporation and its subsidiaries, 2011. In 2002: A very
well done. award-winning annual report. Includes scoresheet filled in (p.112).
Retention =88% (p.113). Value per
technical employee 155.67Rscrore/319,
2001 302.83/1230 (p.114). Trademark valuation (p.115). Economic value added
(EVA) indicators (p.120), value reporting (p.125).
[Musher:00] Steven A. Musher: Cost-sharing of ongoing research and development
(“R&D”) on acquired technology; IRS Field advice, released 7 Jan 2000.
[Nakamura:98] Toru Nakamura: “Profit Theorioes in
Ptasnfer Pricing; Transfer Procing Report, Vol.6, 25 Feb 1998, p. 673.
Nakamura: 99] Leonard Nakamura: “Intangibles: What put the New
in the New Economy”; Federal
Reserve Bank of Philadelphia Business Review, July 1999. corporate investments in tangible
assets have stagnated while corporate value creation has surged at the same
time. The S&P 500 index, reflecting the market value of the major U.S.
corporations, surged between 135.76 at the end of 1980 to 1342.62 on Nov.20,
2000 – a ten fold increase. In the same period investments into tangible assets
in the U.S. (as a percentage of corporate GDP) decreased from 14.1% in the
1980s to 12.6% in the 1990s
[Nakamura:01]‡
Leonard Nakamura: “ Investing in Intangibles, is a
Trillion Dollars missing from GDP”; Federal Reserve Bank of Philadelphia Business Review, Q4, 2001, p27-37, Philadelphia Fed.org,
[Nakamura:08 ] Leonard Nakamura: “ Intangible Assets and
National Income Accounting”; Federal
Reserve Bank of Philadelphia Woking paper 08-23, 16 Oct 2001, SSRN#1285048.
[NakamuraS:11] Emi Nakamura and Jón Steinsson: Fiscal Stimulus in a Monetary Union:
Evidence from U.S. Regions; NBER Working
paper No.17391, Sep. 2011, SRN#1931161. Uses military contracts to firms in
US staes as a model for Stimulus. 1.5 leverage.
Also data on goods vs servoces
[Nakaso:12] Dan Nakaso: U.S. tax
shelter appears secure; San Jose Mercury News, 25 Dec. 2012, p.1,5. <dnakaso@mercurynews.com/
408 271-3648>. $2billion - Approximate ampount ]] saved on worldwide imcome
taxes in 2011 by legally moving $98. in revenues into a Bermuda shell company.
Have. copied.
[Narin:91] Francis Narin: Globalization of Research,
Scholary Information and Patents – Ten-year Linkage Trends.
[NCPA:12] National Center for Policy
Analysis: The Benefits of a Flatter,
Fairer Tax System; NCPA, 7 Dec 2007. Success of the Hong Kong economy under
a flat tax system.
[NCCUSL:85]
National Conference of Commissioners on Uniform State Laws: Uniform Trade Secrets Act with 1985 Amendments; Basic text
for IP protection laws in most states of the U.S. (including AZ, CA. Delaware,
MA, MD, MN, OH , VA) Not Michigan, New Jersey, New York, PA, TX, WY as of 1997.
<http://www.law.upenn.edu/bll/ulc/fnact99/1980s/utsa85.htm
[NDT:11] Nevada Department of Taxation: Federal Income Tax; Nevada Tax Notes, 174, April 2011.
[NeefSC:98]
Dale Neef, Gerald Anthony Siesfeld, and Jacquelyn Cefola, editors: The economic impact of knowledge;
Boston: Butterworth-Heinemann, 1998. (used by Joy Yen).
[NedelkoskaW:10] Ljubica Nedelkoska and Simon
Wiederhold: "Technology,
Outsourcing, and the Demand for Heterogeneous Labor: Exploring the Industry
Dimension"; Jena Economic Research Papers # 2010-52, 2010, Jena
Research group on The Economics of Innovative Change; . (simon.wiederhold@uni-jena.de)
(Friedrich Schiller University Jena, GK-EIC
and Ljubica Nedelkoska (ljubica.nedelkoska@uni-jena.de)
(Research Training Group "Economics of Innovative Change" at the
Friedrich Schiller University Jena), Simon Wiederhold (simon.wiederhold@uni-jena.de)
(Research Training Group "Economics of Innovative Change" at the
Friedrich Schiller University Jena), now in Munich
[NelsonM:97]
Richard D. Nelson and Robero Mazzoleni: economic Theories About the Costs and
Benefits of Patents; in Intellectual
Property In Biomedical Research, National Academies Preaa, 1997. Report contains case study on the Cohen-Boyer
Recombinant DNA patenr.
[Nellen:11]
Anete Nellen: Tax Reform Information;
March 2011; <http://www.cob.sjsu.edu/nellen_a/txrefupd.html>
[NetherlandsTaxRules]
<http://www.lowtax.net/lowtax/html>/offon/netherlands/nethom.html>
[NicolaidisH:01] Kalypso Nicolaidis and Robert Howse (eds.): The Federal Vision:Legitimacy and Levels
of Governance in the United States and the European Union; Oxford University Press, 2001. Ordered.
[Nolan:10] Deborah Nolan: A new chapter in achieving certainty
through alternative dispute resolution; Tax Administration Without Borders,
Issue 5, Oct.2010, Ernst & Young. Jungle quote by Dave Hartnett, HMRC, 2009.
[Norris:11]
Floyd Norris: "Deep roots of the scandal at Olympus"; Wall Street Journal, 9 Dec 2011, p.22. A good explanation
[NorwoodEa:06] Janet L. Norwood (chair) Off-shoring, How big is it?;
national Academy of Public Administration (NAPA). Oct.2006, 274pp.Covers services as
well. Focus in NAICS codes 3254 (pharma), 5413 (architectural) 54125 (computer
design & manufacture) 5614 (business services). Disk copying.
[NPR:11]‡
How Offshore Tax Havens Save Companies Billions; NPR broadcast and summary 17
March 2011;
<http://www.npr.org/2011/03/17/134619750/how-offshore-tax-havens-save-companies-billions?sc=emaf.
Quotes
Drucker, Reed College professor: Kimberly Clausing?
[NTFC:1999] National Foreign Trade Council: “The NFTC Foreign Income Project,” March 25, 1999, p. 6-5. Cited by Edwards:03. Reduction in US registred shipping fleet.
[Oates:72]‡ Wallace Oates: Fiscal
Federalism; Harcourt Brace Jovanovich, 1972.
Introduces
tax competition.
[OatesO:03] Mark
A. Oates and James O’Brien: “For Settlement Purposes Only”; Transfer Pricing , Taxation of Global Transaction, CCH
Wolters, Summer 2003, pp.31-34. Taxpayers should
settle if favorable terms can be negotiated. Settlement analyses are less
precise. Information from failed settlements or APAs is not admissible evidence
at a trial
[OatesO:09] Mark
A. Oates and James O’Brien: “The Arms-length Standard: Why it Matters”;
Transfer Pricing , International
Tax Journal, CCH Wolters, July 2009. Double taxation. Xlinx case arms-length versus
formulary apportionement. Parochial interest of nations. Regulatory History.
[OatesO:11] Mark
A. Oates and James O’Brien: “Lux et Veritas: IRS’s Actions Speak Loader Than
its Words”; Transfer Pricing, International
Tax Journal, CCH Wolters, Jan.2011. Veritas case. “Judge
Foley rejected the IRS theories, ruled the IRS original and trial positions to
be arbitrary, capricious and unreasonable, and accepted the taxpayer’s
comparables-based theory of the case with minor modifications.”. “In order to
win a Code Sec. 482 case, a taxpayer must show that the IRS’s position in the
notice of deficiency was arbitrary, capricious or unreasonable.” “having lost
badly, the IRS’s angst and anger over the decision is understandable.” “To be
absolutely clear, the IRS in the AOD is saying that, given the facts found by
Judge Foley, the IRS too would have ruled for the taxpayer in VERITAS.” “Dr. John Hatch was the principal expert
advanced by the IRS at the trial in VERITAS. The original notice of deficiency
sported an amount 50 percent higher ($2.5 billion buy-in value) than the IRS
trial position based on Hatch’s analysis and opinion ($1.675 billion buy-in
value). The prior notice of deficiency buy-in value was based on the analysis
and opinion of Dr. Brian Becker. Prior to trial, the IRS abandoned Becker’s
opinion, and, at trial, “without meaningful explanation, conceded $825 million
of the [Becker] buy-in amount” and “failed to offer even a token defense in
response to petitioner’s critique of Becker’s conclusions.” Not surprisingly,
Judge Foley found the IRS notice position based on Becker to be arbitrary,
capricious or unreasonable.” “In addition, respondent infl ated the
determination by valuing short-lived intangibles as if they have a perpetual
useful life and taking into account income relating to future products created
pursuant to the [cost sharing agreement] .” “hinges primarily on the testimony
of Hatch. Put bluntly, his testimony was unsupported, unreliable, and
thoroughly unconvincing. Indeed, the credible elements of his testimony were
the numerous concessions and capitulations.” “Hatch further agreed that his
discount rate used to value VERITAS’s earnings into perpetuity, to a reasonable
degree of economic certainty, could not possibly be correct.”” Based on the
failure to appeal VERITAS, the authors believe that Appeals will continue to
assign very high hazards to the IRS in litigation of the buy-in issues and thus
to continue to settle these cases on terms highly favorable to taxpayers.”
[Obama:08]
Barack Obama 2008 ran on a tax plan that included “…reforming deferral to end the incentive
for companies to ship jobs overseas”;
deferring some deductions until repatriation and curbing the “check the
box” regulations that enable multinationals to structure their foreign
operations in a tax-favorable manner, Obama-type
policy statements imply that multinationals somehow benefit unfairly from a tax
system with perverse incentives.4. (<http://www.barackobama.com/pdfl>/taxes/Factsheet_Tax_Plan_FINAL.pdfl>).
See [Weiner:09] ???
[Obama:12] Barak Obama: Startup America Legislative Agenda; 24
Jan 2012, <http://www.whitehouse.gov/sites/default/files/uploads/startup_america_legislative_agenda.pdfl>
[OBrienC:90] James
O’Brien and Robert J. Cunningham: “Protecting Against the Disclosure of Trade
Secrets to Independent Experts and Third-Party fact Witnesses During an
Internal Revenue Service Audit”; Tax Executive, Vol.42, March 1990, pp.99-108. Considers that trade secrets, once
obtained by an IRS agent are not protected when disclosed to third parties
hired by the IRS.
[OBrienEa:98] James
M. O’Brien, Karen A. Kunster, David A. Waimon, John McDonald, David D. Noren,
and Ryan R. Brenneman: U.S. Corporations
Doing Business Abroad; Baker McKenzie, Vol.28 of a series on Tax
Advisors Planning, Research Institute of America, (RIA) Checkpoint, 1 Jan.1,
1998, 376 pp. Have.
[OBrienO:99] James
M. O’Brien and Mark A. Oates: Caveat Expert: Let the Expert Witness Beware; Taxes, CCH, Vol.77 no.11, July 1999. A report should
be filed 60 days prior to a trial. Those lead to rebuttals. Up to a dozen
witnesses in some cases. Experts are easily damaged. Use of junk science. Facts
are better than opinions.
[OBrienO:02] James
M. O’Brien and Mark A. Oates: “Common Sense and the Art of Transfer Pricing”;
Transfer Pricing, Taxation of Global
Transaction, CCH Wolters, Winter 2002, pp.33-34, 63-64. The arms-length standard is understandable to
all and matches market experience. Good motivation.
[OBrienO:02M]
James M. O’Brien and Mark A. Oates: “Musing on Transfer Pricing Developments”;
Transfer Pricing, Taxation of Global
Transaction, CCH Wolters, Summer 2002, pp.19-24, 70-71. DHL case. UPS insurance payments, Xlinx
stockoptions. APa program.
:08] Kevin J. OConnor:
[OdagiriEa:10] Hiroyuki Odagiri, Akira
Goto, Atsushi Sunami , and Richard
R. Nelson.
(eds.): Intellectual Property Rights,
Development, and Catch Up: An International Comparative Study; Oxford
University Press, 2010. At Abe books
45+8.91. And Amaxon $38 Patents may promote innovation and
catch up, and they may foster formal technology transfer. Yet they may also
prove to be barriers for developing countries that intend to acquire
technologies through imitation and reverse engineering. The current move to
harmonize the IPR system internationally, such as the TRIPS agreement, may thus
have unexpected consequences for developing countries. For most countries,
economic development involves 'catching up' with leading countries. This needs
more than physical assets and labour: it requires technological capabilities,
educational attainment, entrepreneurship, and development of the necessary
institutional infrastructure, including intellectual property rights,
particularly patents.
[OECD:86] OECD Committee on
Fiscal Affairs: Double Taxation Convention and the use of Conduit Companies;
OECD, Paris, 1986.
[OECD:98] OECD Committee on Fiscal Affairs: Harmful Tax
Competition, An Emerging Global Issue; Organisation for Economic Co-operation
and Development (OECD), Paris, April 1998.
[OECD:87]‡ Committee on Fiscal Affairs,
International Tax Avoidance and Evasion, Four Related Studies, Issues in
International taxation Series no.1, OECD, Paris, 1987.
[OECD:00]‡ OECD CFA: Clarification on the
Application of the Permanent Establishment Definition in E-Commerce: Changes to
the Commentary on the Model Tax Convention on Article 5; Committee on Financial Affairs Report, 22
Dec.2000, 7pp.= Just having a server in X does not in itself constitute having a permanent
establishment in X. An ISP is not an agent. Have.
[OECD:01]‡
OECD TAG: Attribution of Profit to a Permanent Establishment Involved in
Electronic Commerce Transactions; Technical Advisory Group on Monitoring the
Application of Existing Treaty Norms for the Taxation of Business Profits ,
Draft Report for Discussion, Feb.2001,
34pp.=Example.
Focuses on e-tailing (p.5). In most condition under arms-length principles
having a server in X leaves all substantial assets and risks with the head
office (p.4). If services are provided by an Independent Service Provider (ISP) the conclusion would be similar (p.4.
19-. ). If there is personnel and X
assumes sufficient development risk to be considered an economic owner, then
commensurate profits are to be attributed to X (p.21,28). Comparables (p.23), Problems (p.27)
<have>
[
[OECD:06] OECD,
CTPA: Transactional Profit Methods – Responses to the OECD Invitation to
Comment; Centre for Tax Policy and Administration, 6 Sep.2006. Responses by 15 consulting firms and Corporations.
Follows 1995 OECD TP Guidelines <http://www.oecd.org/dataoecd/17/12/37421921.pdf>
OECD:08T]‡
OECD Committee on Fiscal Affairs, Model Tax Convention on Income and on
Capital, Paris, 2008.
[OECD:09]‡ List
of Unco-operative Tax Havens; OECD 2009. No longer on the site. <http://www.oecd.org/document/57
>. Change to [Makhlouf:02]
[
.Transparency may lead to
shareholder litigation once risks of aggressive tax practices are recognized.
Mentions conduit companies. The value
added chain though ignores IP contributions.
Innovation in science, technology and
industry..<http://www.oecd.org/sti/inno/newsourcesofgrowthknowledge-basedcapital.htmOECD13I]
Supporting Investment in Knowledge capital,
Growth, and innovation.. Uses the term `knowledge-based Capital” (KBC)
where I use Intelectual captal. Talks about tax expenditures forvR&D. Date
on KBC investment.
[OED:02]‡ Oxford
English Dictionary, 2nd Edition, updated on CD: Oxford University
Press, 2002. Intangible - incapable of being touched.
[OGara:10] Patrick
O’Gara: UK Tax residence of Offshore Companies, Laerstate BV v HMRC (2009);
Baker & McKenzie, June 2010, <http://www.bakermckenzie.com/RRUKTaxResidenceOfOffshoreCompanies/> retrieved 16 Dec.2010.
[Ogley:00] Adrian Ogley
(ed.): Tolley's Tax Havens (3rd edition); Tolley Publishing, 2000. ISBN
0754504719. ABA books: 78569216
Have. 4th edition due 2013. Failure to harmonize.
[OHanlon:12]
Michael O’hanlon: The wounded Giant: America’s Armed Forces in an Age of
Austerity; Brookings Intitution, Penguin Press, 2011; Kindle edition, 2012. Good data on
China, DoD.
[Olson:82]
Mancur Olson: The Rise and Decline of Nations: Economic Growth, Stagflation, and Social
Rigidities; Yale University Press, 1982. on Kindle.
[Olson:02] inversion
testimomy cited in PalanMC:10
[Olson:08] Nina E.
Olson: National Taxpayer Advocate: Fiscal Year 2008 Objectives, Report to
Congress, IRS, 30 June 2010, 351pp,
<http://www.irs.gov/pub/irs-utl/tas-ARC_intro-TOC-MSP.pdf>. 3.7M words for the
taxcode, tripled since 1975
[Olson:10] Nina E. Olson:
National Taxpayer Advocate: Report to Congress, Fiscal year 2011 Onjectives; IRS, 30 Jun.2010,
<http://www.irs.gov/pub/irs-utl/irs_tas_arc2011_exec_summary.pdfl>. TAS plans to
use a case complexity measure based 22 different factors by and of 2010
[Olson:10O] Nina E.
Olson: National Taxpayer Advocate: Fiscal Year 2012 Objectives, Report to
Congress, IRS, 30 June 2010, 158pp,
<http://www.irs.gov/pub/irs-utl/nta2011objectivesfinal.pdfl>.
[Olson:11R] Nina E.
Olson: National Taxpayer Advocate: Report to Congress, Fiscal year 2012
Onjectives; IRS, 30 Jun.2011,
<http://www.irs.gov/pub/irs-utl/irs_tas_arc2011_exec_summary.pdfl>. Focus on TAS. Human Capital: More training
needed for taxpaper advocacy
[Olson:11] Nina E. Olson:
National Taxpayer Advocate: 2011 Report to Congress; IRS, 31 Dec.2011,
<http://www.irs.gov/pub/irs-utl/irs_tas_arc2011_exec_summary.pdfl>. `Kafka-esque
U.S. International tax regime’. Limited audit resources. Inadequate funding,
reduced each year. Ianabilty to have programs in place for the 2011 filing
seansn because congress legislation was late. Imbalance. Effort to rewrite
computer code for each new law and regulation. Taxgap[ $2,680 per household. [
Without international] Undermine effrectiveness of international enforcement. Globalization problem. Work
needed to write regulations.
[OMahonyT:09]
Mary O'Mahony and Marcel P. Timmer: "Output, Input and Productivity Measures at the
Industry Level: The EU KLEMS Database“; Economic Journal, Royal Economic Society, Vol.119, no.538, , 2009 pp.F374-F403.
[OMB:05] Fiscal Year 2005, Analytical perspectives,
Budget of the U.S. Government; Office of Management and Budget (OMB), Feb.2004 Annual report. Analyzes crpotrate taxation as a negative tax expenditure.of
about $2 35B
[OMB:11A] OMB Fiscal Year
2012, Historical Tables, Budget of the U.S. Governments; Office of Management
and Budget (OMB), 14 Feb.2011,
<budget.gov>. [xls/taxes]
[OMB:11B] OMB’s 2012 Mid-Session Review, Budget of the U.S.
Government; Office of Management and Budget (OMB), 1 Sep.2011 <budget.gov>. See Table S-2, p.
25. Capital gains 2012-20021 $168B,
capital gains + dividend $760B 2012-2021 [xls/taxes]
[OMB:12A] Fiscal Year 2012,
Analytical perspectives, Budget of the U.S. Government; Office of Management
and Budget (OMB), <budget.gov>. Annual report. Tax expenditures in pages 239-241,
continued p.255. Tables in HMAT.xls..
[OMB:12B] Fiscal Year 2013,
Budget of the U.S. Government; Office of Management and Budget (OMB),
<budget.gov>. full budget NSF [p 187] . Numbers astart at [p205]
[<http://www.online-publishers.org/
[Ordonez:13]
Patricia Ordoñez de Pablos (University of Oviedo, Spain), Robert D. Tennyson
(University of Minnesota, USA) and Jingyuan Zhao (University of Québec at
Montréal, Canada): Intellectual Capital Strategy
Management For Knowledge-Based Organizations; To be published by IGI Global
http://bit.ly/w7eTgZ
[Orrel:10] David Orrel: Economyths: Ten Ways Economics Gets It Wrong; Wiley, 2010.
Critique of `neoclassical economic reasoning’. Most modles assume stability about a normal
mean. more realistic is a power law distribution. Stll accepts symmetry
there.Favors agent-based modles.Have.
[OshriKW:07] I. Oshri, J.Kotlarsky, and L. Willcocks: “Managing Dispersed
Expertise in IT Offshore Outsourcing: Lessons for Tata Consultancy Services”; Management Information Systems Quarterly
Executive (MISQE), Vol.6 no.2, June 2007.
[OskolkovaN:12] Marina Oskolkova and Iuliia Naidenova: Impact of Intellectual Resources on
the Value Growth of Companies; Higher School of Economics University, Perm,
Russia, 4th European Conference on
Intelectual Capital, Finland, Academic Publishing International Limited,
2012.
[OsterB:02] Christopher
Oster and Ken Brown: AIG, A Complex Industry, A Very Complex Company; The Wall Street Journal. 23 Jan.2002. 250 subsidiaries.
[OTA:86] Office of Technology Assessment: Research
Funding as an Investment, Can we Measure the Returns: Technical Memorandum
SET-36, OTA, US Congress, April 1986. The answer is
essentially No.
[OTP:07] Office of Tax Policy: Approaches to Improve the Competiveness of the
U.S. Business Tax system for the 21st Century; U.S, Department of
the Treasury, 20 Dec.2007 . Importance of recognizing global flow. Coniders effect of
depreciation. Business Activities Tax (BAT) (not BATSA ) Repeal the corporate
tax and replace it with a VAT of 5 to 6%. Graph shows lead of smaller OECD
countries.
[Overby:07] Stephanie Overby:
“ABC: An Introduction to Outsourcing”; CIA magazine, 9 March 2007, www.cio.com/article/40380/
Outsourcing_Definition_and_Solutions#1.
[Owens:07] Jeffrey Owens
Hearing on Offshore Tax Evasion: Stashing Cash Overseas; S. Finance Comm. on Offshore Tax Evasion,
110th Cong. 5, 2007, available at http://www.ceff.univ-cezanne.fr/documents/owen.doc>. Jeffrey Owens,
Director, OECD Center for Tax Policy and Administration; Our research reveals
that only four OECD countries (Mexico, Sweden, the United Kingdom and the
United States) regularly publish estimates of the tax gap. . . One reason why countries are reluctant to
calculate any possible tax gap is that there is no agreed methodology to
measure the gap. OECD is currently undertaking work in this area.
[Oxfam:00]
Oxfam: Tax Havens: releasing the hidden billions for poverty eradication, Oxfam
UK All--‐Party Parliamentary Group on Africa, 2000, From
Vaibhav CS207
Why the Tumblr Deal Is a Disaster for Entrepreneurs
[OzimT:10] Tola
Ozim and Edward Tanebaum: H.R. 5328: International Tax Competitive Act of 2010;
International Tax Advisory, Allston+Bird, 15 July 2010. Provisions of the Stop Tax Haven Abuse Act
have been picked up in the Bill.
[PackmanC:11] Andrew Packman and Augusto Lopez Claros: Paying Taxes
2012, the Global Picture; Price Waterhouse Coopers and the World Bank, 2011. www.pwc.com/payingtaxes. Also John Preston, Neville Howlett, Sylvia Solf, Tea
Trumble. Focus on small and medium sized businesses in 183 economies. .
Companies consider tax rates. Tax cost world wide 44.8% of its commercial
profits. 277 hours to comply for sample
company. Average total tax rate has fallen by 8.5%, > 1%/yesr. 10 economies
do not levy a corporate tax, and in 3 no tax is paid because of reliefs and
allowances. Income tax represents just
12% of all corporate taxes. US effective
tax rate 27.6%, average global rate 16%
(weighted?)
[PakesS:79]
Ariel Pakes and Mark Schankerman: Rate of Obsolescence of Knowledge, Research
Gestation Lag, and the Private Rate of Return to Research Resources; NBER
working paper no.346, May 1979. In [Grilliches 84, pp.73-88] as Rate of
Obsolescence of Patents, Research Gestation Lag, and the Private Rate of Return
to Research Resources. Lag is 6 month a
[Palan:02]
Ronen Palan: “Tax Havens and the Commercialization of State Sovereignty”; International Organization; Vol.56 no.1,
2002., pp.151-176.
[Palan:06] Ronen Palan: The Offshore World: Souvereign markets,
Virtual Places, and Nomad Millionaires; Cornell University Press, 2006. Have -
<+ch10>
[PalanMC:10] Ronen Palan, Richard Murphy, and
Christian Chavagneux: Tax Havens: How Globalization
Really Works; Cornell Studies in Money, 2010, www.cornellpress.edu. Tax havens are
continually evolving. Covers criminality, transfer pricing, but not IP.
Corporations owning other corporations first in Holland, 1893, and then in New
Jersey 1899.
[Palda:64] “Classic work on the cumulative effects on
advertising” used as test Lydia Pinkham’s tonic data, a company which spent some years 85% of its sales on advrtisment,
but was <attacked> by government agencies during prohibition, since the
prime ingredient was alcohol.
[PanditS:08] Vivek Pandit and Rajesh Srinivasaraghavan: ”A fresh wind for offshoring
infrastructure management”; McKinsey Quarterly, Oct.2008.
[PapadimitriouEa:11]
Panagiotis Papadimitriou, Hector Garcia-Molina, Prabhakar Krishnamurthy, Randall
A. Lewis, and David H. Reiley, "Display Advertising Impact: Search Lift
and Social Influence"; Proceedings
of the 17th ACM SIGKDD Conference on Knowledge Discovery and Data Mining
[KDD'11] , 2011 pp.1019-1027. Read the abstract. Download the manuscript.
[Parker:87] Rachel
Parker: “’Secured facility’ solves compatibility Conflicts; Info World, 28 Sep.1987 – reference for
clean room softwar e. I used a better one once? in lag paper
[ParilloE:12] Kirsten A.
Parillo and Amy S. Elliott: IRS to withdraw Coordinated Issue Paper on
Cost-Sharing Arrangement Buy-in Adjustments; Tax Notes Today, Tax Analysts, TNT 13-2,
19 Jan 2012.
[Parnas:94]†
David Parnas: "Software Aging"; 16th Conf. on Software Engineering,
May 1994, pp.279-287.
[Park:92]†
Robert
E. Park: "Software Size Measurement: A
Framework for Counting Source Statements"; Software
Engineering Institute,
Technical
Report CMU/SEI-92-TR-20.
[Parr:07] Russell Parr: Royalty
Rates for Licensing Intellectual Property; Wiley, 2007; Kindle edition,
2007. On Kindle. Reports
royalties/op. profit margins for SW 6.8/18.8%, for electronics, 4.0/8.8%, for
computers 4.0/6.9%, and for healthcare 4.8/14.8% in terms of revenues.
Trademark royalty are a median of 5%. Also reports that 88% of licenses have
underreported royalties [Ex.14.1] , and that internal royalties rates are
typically meaningless because of manipulation for tax reasons [ch.4] . Rambus
charges 3.5% of DR DRAM technology use [Chap.3] . Cites Royalty Source
statistics. [xls/comparables]
[ParrS:96]
Russell L. Parr and Patrick H. Sullivan: Technology
Licensing: Corporate Strategies for Maximizing Value; Wiley 1996. Chap.14
for IC, IP definitions cited in [SmithP:05] .
[ParrS:05] Russell L. Parr and Gordon V. Smith: Intellectual Property; Valuation,
Exploitation, and Infringement Damages, 4th Edition; Wiley;
Adobe E-book, May 2005.
[Paschall:00]
C. Thomas Paschall: U.S. Capital
Gains Taxes: Arbitrary Holding periods, Debatable Tax rates; USC Law Revue, Vol.73, 2000. <P 843-<http://www-bcf.usc.edu/~usclrev/pdfl>/073404.pdf>.
[Paul:10]
Ron Paul: The Case for Gold, A
Minority Report of the U.S. Gold Commission; Laissez Faire books, 2001,
reprint of a 1983 report.
[Paul:12]
Ron
Paul: Plan to Restore America; Ron Paul Presidential Campaign Committee, 2012. Actually
has numbers and totals. [xls/taxproposals]
[PaulEa:03]
Lindy L. Paul (chief of Staff) et al.: Report of Investigation of Enron
Corporation and Related Entities Regarding Federal Tax and Compemsation Issues,
and Policy Recomendations; Joint Committee on Taxation, Senate Committee on
Finance, JCS-3-03, Feb.2003, 385pp.3,500 subsidiuaries. Taxes only in 2000, $62M on 101B
in revenues.
[Payne:93] James L.
Payne: Costly returns; The Burdens of the
U.S. Tax System; Institute for Contemporary Studies (ICS) press, Jan. 1993. Have. Refers [ADLittle:85]‡.
Adds many more amounts [W:12, IRSdata]‡. Estimates total cost of tax
preparation at $159B or 65% of actual collections. Diatribe. [xls/irs]
[Pearlman:11]
David Pearlman, on Charlie Rose Friday night 7 Jan 2011: In the global economy
there is no assured connection between income growth of Multinational
Corporations and job growth in any particular country.
[Pearlstein:11] Steven
Pearlstein: Charlie Rose Interview: Facebook, jobs; at 40 min, Audio Books, Audible.com, 10 Jan
2011. Have
[Pearlstein:13]
Steven Pearlstein: “Marty Sullivan
figured out how the world’s biggest companies abvoided billions in taxes.
Here’s how he wants to sop thwm”; Wonkblog, Washington
Post, 26 Oct. 2013. .[ACM].
[PearS:11] Robert Pear and Jennifer Steinhauer: “Senate Approves
Two Pieces of Jobs Bill”; The New York
Times, 10 Nov 2011. Veterans jobs
[Pearson:06] Thomas C. Person:
“Preparing Multinational Companies for Tranfer Pricing Audits of Intangibles”; International Law & Management Revirew,
BYU, Vol.2, pp.159-200, 2006. “While
most multinational companies will usually not disregard the law, some believe
their business strategies may place them dangerously close to questionable
areas that exploit legal loopholes.84 The natural, but unfortunate, result is
that governments require more detailed transfer pricing audits to ensure that
multinational companies comply with a country’s transfer pricing legal
requirements and the spirit of its law.”
Risks among parties. Clauses for comparables. Identify tax-planning
opportunities. Division of intangibles is likely an improper pricing tactic.
361 deals with spit intangibles only. APA program. Mutual concession settlements. Location savings.
Significant taxpayer victories. Compamy will usually achieve partial success in
litigation.
[Peel:11]‡
Michael Peel: Tax Havens: In a sea of trouble; Financial Times, 12 Jan.2011. On BOTs
[PeppardD:07]
J. Peppard and E. Daniel: “Managing the Realization of Business Benefits from
IT Investments”; Management Information Systems Quarterly Executive
(MISQE); Vol.6 no.1, March, 2007.
[Perry:11] Rick Perry: “My Tax and Spending Reform Plan: Cut,
Balance, and Grow”; Wall Street Journal;
26 Oct 2011. Corp tax 20%
[PfatteichervTF:07]
Linda Pfatteicher, Bernhard von Thaden, and Paul Flignor: IRS again attempts to rein in cost-sharing
arrangements; DLAPiper International Tax Newsletter, Oct.2007.
[Philips:89] Louis Philips: The Economics of Imperfect Information; Cambridge Univ. Press,
1989. Predatory pricing and Foregone profits
pp212-242 for a monopoly versus a prey..
[Philips:12] Mathew
Philips: “Time to Head Home for Some Manufacturers”; Bloomberg Business Week, 6 Feb 2012. Total cost differential is reducing.
Consider risk of IP loss – still not quantified.
[Phillips:11]
Michael R. Phillips: Reducing the Processing Time Beteween Balance Due Notices
Could Increase Collections; IRS, TIGTA , 26 sep. 2011. Obvious, already stated by Rossotti. After 12 months,
collectability falls to 23 percent. The notice stream could potentially collect
an additional $363.4 million, based on the 11.6 million balance due modules
that entered the notice stream during FY 2010.
[Pickle:92]
J.J. Pickle: Tax Underpayments by U.S. Subnsidiaries of Foreign Companies;
Hearings before the Oversight Committee of the House Committee on Ways and
Means, 102 Congr, 2nd session, 1992. “The IRS was simply oputgunned and out
maned”
[PierceS:09] Justin R. Pierce
and Peter K. Schott: A Concordance Between Ten-Digit U.S. Harmonized System
Codes and SIC/NAICS Product Classes and Industries; Center for Economic Studies, U.S. Bureau of
the Census, Nov.2009.
[Pigoski:97]† Thomas
M. Pigoski: Practical Software
Maintenance - Best Practices for Managing Your Software Investment; IEEE
Computer Society Press, 1997.
[PimentelG: 94] David Pimentel and Mario Giampietro:
Food, Land, Population and the U.S. Economy ;Nov.21, 1994. Carrying Capacity
Network, in [Hanson:11] , dieoff, resource depletion
[PiotrowskaV:08] Joanna Piotrowska and Werner Vanborren: "The corporate income tax rate-revenue
paradox: Evidence in the EU“; Taxation
Papers 12, Directorate General
Taxation and Customs Union, European Commission, revised Oct 2008.
[PisanoS:09] Gary P. Pisano and Willy
C. Shih. "Restoring
American Competitiveness"; Harvard Business Review 87, nos. 7-8
,July – August 2009.
[PMI:00] Project
Management Institute: Project Management Body of Knowledge Guide; Project
Management Institute, 2000.
[Polanyi:44] Karl
Polanyi: The Great Transformation; Boston: Beacon press, 1944. unfettered free
trade is fundamentally incompatible with social order and stability. On Kindle
[Politi:11]
James Politi: “White House chief defends `Buffet rule’”; Financial Times, 19
Sep.2011.
[Polk:06]
Michael Polk: "It's all about Dislocationg Ideas"; Knowledge@Wharton, 15 Nov 2006, <http://knowledge.wharton.upenn.edu/article/1604.cfm
.
[PollinG:09] Robert Pollin and Heidi
Garrett-Peltier: The U.S. Employment Effects of Military and Domestic Spending
Priorities: A n Updated Analysis; Political Economy Research Institute, Univ.
of Mass, Amherst, Oct 2009.
[Pollock:12] Lisa Pollock: “Tax arbitrage 101”; Financial Times, 25 May 2012. Tax case IRS vs HP Foreign Tac Credit generator , 4-part series: Inefficient market
hypothesis, the genesis of a transcation, the anatomy of a transction (with
picture, stroopwafels and cheese), The defeast of An FTC generator. Much friction and inefficiency. Uses the
Netherlands, uses Dutch tax letter,
[Pomeranz:00]
Kenneth Pomeranz: The Great Divergence: China, Europe, and the Making of the
Modern World Economy.; 2000, ISBN 0-691-09010-6.
[Ponting:07] Clive Ponting: A New Green History of the World: The Environment and
the Collapse of Great Civilizations.; Penguin Books, 2007.
[PopperL:85] Karl R. Popper & Konrad
Lorenz:,Die Zukunft ist Offen;
Franz Kreuzer ed., 1985. p.74 `arguing that some structures, like airplanes, contain
so many ideas that they are not comprehensible to anyone individual; hence they
require collaboration) (translated with the assistance of Oliver von
Schweinitz, LL.M. 2(03);[(Schwarz:10, on ENRON)
[Porter:90]
Michael E. Porter: The Competitive Advantage of Nations ; The Free
Press, Simon and Schuster, 1990. Kindle chapter on PC, “Government must not limit
competition or ease standards for safety and environmental impact. Such `help’
actually retards competiveness by stunting innovation and slowing productivity
improvement”
[Porter:98]
Michael E. Porter: Competitive Strategy; The Free Press, Simon and
Schuster, 1998.
[Porter:11] Eduardo
Porter: The Price of Everything: Solving the
mystery of Why We Pay What We Do;
Portofolio, 2011. The price of a human life oy year of life (QALY). happiness metrics. WEll
indexed. Patents, Copyright, and Labor, The price of free.
[Porter:12]‡ Eduardo
Porter: “Loopholes to Some, Lifelines
to Others”; NYT, 11 dec.2012. Clinton invented
with the $40 billion worth of Higher Education Support over five years, tucked
into the 1997 Taxpayer Relief Act. the use of tax deductions to support
education.
[Posner:77] Richard A. Posner: Economic Analysis of Law; Little, Brown,
1977. The
more precise a rule is, the more likely it is open up loopholes – to permit by
implication conduct that the rule was intended to forbid. See also
TaxPolicyCenter11.
[Post:13] Rick Post: Why
Microsoft opened their Europena HQ in Ireland; Gateway to Europe Expo 2013, San
Francisco, 17 April 2012. The Irish
government is very flexible. ..[ACM]..
NBER Book Series Tax Policy and
the Economy; NBER. Vols.6-23, 1992-2009.
[Pozen:11] Robert C. Pozen: Gingrich’s Flawed Social Security
and Income Tax Proposals; Brookings Opinions, 27 Dec.2011. An
analysis of some effects of tax changes. Gingrich flat tax plan plan promises $850billion
over 10 years. 91 [xls/taxproposals]
[
[PrattRS:96] Shannon P. Pratt, Robert F. Reilly, and Robert P.
Schweihs: Valuing a Business, The Analysis and Appraisal of Closely Held
Companies, 3d ed.; Irwin
Professional Publications, 1996. Reilly's own treatise on business valuation states
that "[c] apitalization of revenues is applied most frequently to service
businesses, such as advertising agencies, insurance agencies, mortuaries,
professional practices, and some types of publishing operations. It generally
tends not to work very well for manufacturing companies”;p.227 . Many
traditional methods for simple cases. Cost-based methods. Life computations based on experience, as
customer retention.
[Pressman:01]†
Roger Pressman: Software Engineering, A Practioner's Approach; 5th edition;
McGrawHill, 2001. [Protalinski12] Emil Protalinski: Last
Facebook Pre-IPO Valuation is Biggest yet: $102.8 billion; ZDNet, 30 Mar.2012. [PrzysuskiL:05] Martin Przysuski and Srini Lalapet: “A Comprehensive
Look at the Berry Ratio in Transfer Pricing”; Tax Notes International, Tax Analysts, Vol.40 no.8, 21 Nov.2005, p.759. Comments on US
and OECD expectations. History of the Berry ratio and the 1979 Dupont case,
[
[PugsleyH:11]
Pugsley, Benjamin and Erik Hurst: “Wealth, Tastes, and Entrepreneurship”;
University of Chicago, Mimeo, 2011. Non pecuniary benefits in small businesses
<request>.
[Pujol:10] Nicolas Pujol, “Freemium: attributes of an emerging
business model”; Social Science Research Network,
11 Dec. 2010, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1718663.
. from Sonny Chan CS207.
[QFA:11]
QFA: Global Finacial Centers; Qatar Finacial Authoritity, Sep.2011. Much data.
<check if relevant>
[QuickDCF:07]
Perry D. Quick, Timothy L. Day, Brian J. Cody, and Susan R. Fickling: “Using
the Market Capitalization Method To Value Buy-Ins: Beware of ‘Thing Three”; Transfer Pricing
Report, vol.14 no 2 July 2005; Distributed by BNA 2007. In Weissler file. Argument
agains market cap. Valid if allocation is neded. Some of the objections are
dealt with by removing tangibles Refers to [Morgan:99] . Thing 3 is
options; Thing 1 is stuff ready to
sell, and Thing 2 is the SW code base for us. Refers to Weissler Cost-Sharing
report. 6 Weissler, Robert, ‘‘E. APA Program Training on Cost Sharing Buy-In
Payments,’’ 11 Transfer Pricing Report 533, 10/2/02. Refers to Option values as
`thing Three’ and argues they should not be included in the transfer price,
although they are included in the market price.
[Quiggin:98] John Quiggin: “Individual
and Household Willingness to Pay for Public goods”; American Journal of Agricultural Economics, v80, n1, (Feb 1998),
58-64. ... in the presence of “non-paternalistic altruism towards
family members, the sum of private willingness to pay for public goods will
equal household willingness to pay which is less than the sum of individual
willingness to pay”; This implies that the estimate of the aggregate
benefit from public goods will be greater than the willingness to pay of the
households as a whole when individual willingness to pay is used as a basis for
benefit estimation. Quiqqin’s
findings help explain the rejection of the Reagan Administration’s argument for
eliminating corporate income tax. In the context of shareholders and
corporations, the shareholders and the corporation can be construed as members
of the same household, with the concern about taxation of corporate income a
consequence of the household's willingness to pay being less than the benefits
accruing to individual household members. Since both the corporation and
the shareholders benefit from public goods, the elimination of the corporate
income tax would reduce the tax burden on the household without reducing
benefits.
[ Tax Reform, not
Fiscal Protectionism, is the Right Response to Corporate Flight: CF&P
Reiterates Call for Territorial Taxation.Washington (March 12, 2002) – The
Center for Freedom and Prosperity, the nation's leader in the fight for
international tax competition, announced today that it will vigorously resist
all legislation to restrict the freedom of companies to locate in jurisdictions
that have more attractive tax and regulatory environments. Andrew Quinlan,
President of the Center, remarked, "Fiscal protectionism is bad policy,
and the Center for Freedom and Prosperity will oppose and work vigorously to
defeat any legislation introduced to stifle tax competition. Tax competition is
a liberalizing force in the world economy. It should be celebrated to
persecuted”; Quinlan explained that, "High-tax California should not be
allowed to stop companies from moving to low-tax Nevada, and Washington
politicians likewise should not be able to stop companies from escaping bad
U.S. tax law”; Tax Reform, not Fiscal Protectionism, is the Right Response to
Corporate Flight: CF&P Reiterates Call for Territorial Taxation
<http://www.freedomandprosperity.org/press/p03-12-02/p03-12-02.shtml>.
[Radaelli:03]‡
Cladio M. Radaelli: The Code of Conduct Against Harmful Tax Competion: Open
Method of Coordination In Disguise;
Public Administration, Vol.81, no.3, 2003. Draft 1999. OMC.
[RaedlerJ:84] Albert J. Raedler and Friedhelm Jacob: German Administrative Principles Concerning Transfer Pricing;
English translation; 1984.
[Raensch:10]
Ullrich Raensch: Handling Tax
Controversies in Europe; Baker &
McKenzie, Tax Europe, Frankfurt 2010.
Rajan:11] Raghuram G. Rajan: Fault Lines, How Hidden
Fractures Still Threaten the World Economy; Princeton University Press, Aug.2011 . On
Kindle &
Paper. Good description
of interaction of Government, private initiatives, and politics. [RRRR] .
Organizational capital. Have on Kindle.
[RamelliEa:12] Rudolph
Ramelli et al.: Comments and Recommendations for Guidance to the Transfer
Pricing of Related Party Guarantees; American Bar Association, letter to
Commissioner Shulman, 13 Sep. 2012, 93 pp. For related party guarantees
“market-based pricing should always be
the starting point”.
Better than yield.
~income. Should apply to loans guaranteed by parent. 93 pp.[xls/irs]
[RanganathanB:07]
, C. Ranganathan and S. Balaji:
“Critical Capabilities for Offshore Outsourcing of Information Systems”
Management Information Systems Quarterly Executive (MISQE), Vol.6 no.3,
Sep.2007.
[Rao:04]
M.T. Rao: “Key Issues in Global Outsourcing: Country and Individual Factors”; Information Systems Management, Summer
2004, pp 16-21.
[Rashkin:07] Michael Rashkin: Practical Guide to Research and Development Tax Incentives: Federal, State, and Foreign, 2nd Edition; CH Wolters Kluwer Publications, 2007. "The Joint Committee on Taxation estimates that in 2004 U.S. corporations will use the research credit and R&D expensing to reduce their tax liabilities by 9.2 billion dollars. The perception used to be that the high-tech sector was the only heir to this tax fortune. But the Treasury Department liberalized the rules, as reflected in the 2001 proposed regulations, and now even traditional manufacturing industries are capitalizing on the research credit and R&D expensing. While maximizing these tax incentives saves companies huge sums of money, the credit in particular can represent a very confusing area of law. Both business people and their tax advisors may be unclear about the rules and how to use them to secure the greatest tax savings. Michael Rashkin, J.D., LL.M., (General Tax Counsel for Marvell Semiconductor, Inc.) provides something that has been missing in professional tax literature--authoritative, comprehensive coverage of this complex and evolving topic. It explains the elements of qualified research, exclusions, computational rules, and basic research payment credits. Historically, the IRS has been vigilant in denying R&D credits. This resource explains how to satisfy the IRS's requirements, document the credit, and defend against IRS challenges. It also examines research incentives offered by individual states and describes the R&D incentives available in the major economies of the world, offering helpful charts that show the key differences among the various countries”;
[Rasmus:06] Jack
Rasmus: the War at Home: the Corporate
Offensive from Ronald Reagan to George W. Bush; Kyklos Productions, San
Ramon, 2006. Have. Corporate America
versus the Unions.
[RauG:12] Aswath
Rau and Pallabi Ghosal: “Entering the Tiger’s Den: Foreign Investment in India through
Mauritius or Singapore”; Singapore Law
Gazette, Feb.2012. Roundtripping cases.
[Rauch:92]
Jonathan Rauch: ; I found a 1992 < <http://www.jonathanrauch.com/jrauch_articles/demosclerosis_the_original_article/>. article that used the word demosclerosis:
[Rauch:94] Jonathan
Rauch: Government’s End, Why Washington
Stopped Working; Public Affairs, Perseus Publishing, 1994. Tragedy of the
Commons elaborated. Blames demosclerosis. Quotes Mancur Olson, Francis Fukuyama.
The implicit assumption has been that whenever markets fail the government will
do a better job. That is an odd assumption. This book is basically an
introduction to public choice theory. It explains how special interests corrupt
government. For a more sophisticated version see The
Myth of the Rational Voter: Why Democracies Choose Bad Policies (New Edition)
[Rauch:05]
Jonathan Rauch: Government's End; 2005.
The implicit
assumption has been that whenever markets fail the government will do a better
job. That is an odd assumption. This book is basically an introduction to
public choice theory. It explains how special interests corrupt government. For
a more sophisticated version see The
Myth of the Rational Voter: Why Democracies Choose Bad Policies (New Edition)
[RavenscraftS:82]
D. Ravenscraft and F. M. Scherer: “The lag structure of returns to research and
development”; Applied Economics, Vol.14,
Issue 6, 1982 pages 603-620,
DOI:10.1080/00036848200000036
[Rawls:71]
John Rawls: A Theory of Justice ; 1971. states, peoples,
soveirgnty
[Raymond:01] Eric
S. Raymond: The Cathedral & the Bazaar: Musings on Linux and Open Source by
an Accidental revolutionary; O’Reilly, 2001.
{ACM]
[Razgaitis:99]‡
Richard Razgaitis: Early-Stage Technologies: Valuation and Pricing
(Intellectual Property – General, Law, Accounting & Finance, Management,
Licensing, Special Topics); Wiley, Intellectual Property Series, 1999.
[Razgaitis:03] Richard Razgaitis: Valuation and Pricing of Technology-Based Intellectual;
Wiley, 2003. Have Kindle edition 2003. 2nd
edition of [Razgaitis:99]‡
[Razgaitis:03D]‡
Richard Razgaitis: Dealmaking Using Real Options and Monte Carlo Analysis;
Wiley, 2003.
[Razgaitis:09]‡
Richard Razgaitis: Valuation and Dealmaking of Technology-Based Intelectual
Property: Principles, Tools and Methods, 2nd Edition; Wiley, 2009. 2nd edition of [Razgaitis:03D]‡
[KrattingerKG:09]‡ Anatole
Krattinger, Stanley Koalski, and Grogory Graff (eds.): ipHandbook of Best
Practices; MIHR, PIPRA, http://www.iphandbook.org/handbook/index.html. has
Chapter 13.2 by Jon Sandelin on Spinout companies.
[RazinS:89]
Assaf Razin and Efraim Sadka: "International Tax Competition and Gains
from Tax Harmonization”; NBER Working Paper No.3152, Oct.1989.
[RazinS:90] Assaf Razin and
Joel Slemrod, eds.: Taxation in the global economy; NBER, University of
Chicago Press, 1990. Several solid
papers. No specific mention of taxhavens. Have. New edition in 1992.
Reich:11] Robert B. Reich: Aftershock, The Next Economy &
America’s Future; First Vintage Books, 2010, updated 2011. Only 1 cite for tax haven – individual. None
for IP. Loopholes. Middle class income drives consumption and the economy.
Strong reverse tax for low income,
carbon tax. College loans to match expected earnings, universal Medicare.
Capital gains tax. Have. Competing
authors have used the term Aftershock and claimed NY times bestseller
status. 91 [xls/taxproposals]
[Reich:11T]
Robert Reich: The truth about the Economy In 2 Minutes; Move-on video, 14 Jun 2011,
<http://front.moveon.org/scribbling-sharpie-illustrates-the-truth-about-our-economy/
[Reich:12] Robert
Reich: Beyond Outrage: What has gone
wrong with our economy and our democracy, and how to fix them; Knopf,
Random House digital, May 2012, 87 pp.Have on Kindle.. Connecting a fw dots. $50B caritable
deductions.
[ReillyS:98] Robert F. Reilly, and Robert P. Schweihs; Valuing
Intangible Assets; Irwin Library of Investment and Finance; McGraw-Hill, 1998. Have copy of
Chapter 1, p.3:29: Identification Defines IP p.20-22; and Chapter 19, p
363-380: Data Processing Intangible Assets, Special Consideration on Software
Valuation, Cocomo 1981”;The Discounted cash Flow method is typically used in
the valuation of data-processing intangibles when there is an identifiable
income stream associated with the intangible asset. Therefore, this method is
usually used in the valuation of product software or databases that generate income
through their sale or license"
"... the economic life of software is an entirely different issue
[from the life for income tax depreciation or amortization] . The analyst
should consider a number of factors, including: o the age of the software and
maintenance or enhancement practices". The market for the software. "
[p.370] . "... physical
deterioration is not generally applicable to data-processing intangibles
... . Functional obsolescence is often
immaterial when the software is continually maintained and enhanced"[p.372]
. “human capital intangibles” consist of
“trained and assembled workforce” and various contracts such as non-compete
agreements, all having possible separate and quantifiable value. They consider
goodwill to be a separate intangible. Intellectual property, for the authors,
is a separate category still, characterized by creativity/innovation and by
separate legal recognition/protection.[?]
[ReinhartR:09] Carmen
M. Reinhart and Kenneth S. Rogoff: This
Time is Different, Eight Centuries of Financial Folly; Princeton University
Press, 2009. On Kindle.
[the American Economic Review Papers and Proceedings,
[Reuters:10] <??> Flextronics sees Pressure on operating margins, 8 Sep.
2110 . 3.5%.
Foxconn, Hon Hai Shares fall on weak earnings 31 Aug 2010 .
[Reuters:12]
“IRS gets its own swat team”; Reuters , 22 Mar.2012. Report on maruca appointment by Dolan, KPMG, ex IRS .
Hiring people from accounting firms for transfer procibnnfg, 40 on-board, 60 to
come. Questiions if resources are sufficient.
This competition has a logical end – the abolition of corporate taxes altogether.` This competition has a logical end – the abolition of corporate taxes altogether. Swiss author Philipp Löpfe, for one, champions such a reform. With abolition, he says, the cantons will stop competing with one another. Instead, the competition will become Switzerland versus the world. Swiss author Philipp Löpfe, for one, champions such a reform. With abolition, he says, the cantons will stop competing with one another. Instead, the competition will become Switzerland versus the world.’
[RhoadesL:12] Rufus
von Thulen Rhoades and Marshall J. Langer: International
Taxation and Tax Treaties; Mathew Bender Co, Lexis Nexis, 2012.
RIA:91] RIA:
Research Institute Master Federal Tax Manual with Federal Tax Coordinator 2d
edition; Research Institute of America, inc., 1991.
[RIA:03] RIA federal tax handbook, 2004; Research Institute of America, inc., 2003.
[Ricardo:1817] David Ricardo: The Principles of Political Economy and
Taxation; 1817; Kindle edition, 2010. On Kindle
[Ricardo:08]
David Ricardo: Free trade, from USA Today blog of 21 March 2008 by
econ_girl: See Ricardo.docx
[Ricardo:13]
Lorenzo Ricardo: Chinese Tax Law and International Treaties, Springer, 2013,
282pp.. Covers
1 Jan.2008 laws on Corporate (Enterprise) taxation. Rate is moving to 25%. Also 3% VAT, There is a
5% Business tax on sales of intangibles and Real estate. Has 13 pages on
transfer pricing.
[RICS:04] The Royal Institution of Chartered Surveyors: The
Value of Intellectual Property, Intangible Assets And Goodwill, 26 Oct.2004, <http://www.rics.org.uk/Property/Propertyappraisalandvaluation/iprvaluation.htm:
"Methods
for the Valuation of Intangibles
Acceptable methods of the valuation of identifiable intangible assets and
intellectual property fall into three broad categories. They are either
market based, cost based, or based on estimates of future economic
benefits. Cost based methodologies, such as the cost to create or the
cost to replace, assume that there is some relationship between cost and value
and the approach has very little to commend itself other than ease of use”;
[RicuperoEa:00]
Rubens
Ricupero (Sec.gen.) et al.: Tax inventives and Foreign Direct Investment: A
Global Survey; United Nations Conference on Trade and Development, ASIT
Advisory Studies, no.16, 2000. Deloitte and Touched fid the survey.
[Rietz:89]
T.A. Rietz: Continuous Time Research and Development Investment and Innovation,
Effects on Price and Dividend Paths; Discussion paper 1012, Northwestern
University Center for Mathematical Studies in Economics and Management Science,
Aug.1989.
[RileyV:12] Michael Riley and Aslee Vance: It’s not Paranoia If
They’re Stealing Your Secrets; Bloomberg
Businessweek,19 March 2012, pp.76-84.
[RistucciaEa:11]
Henry
Ristuccia et al.: Effective Integration, enhanced decision making, the Risk
Intelligent tax executive; Risk Intelligence Series, Issue No.17, Deloitte Development LLC, 2011. Transfer Pricing
Models.
[Ritholtz:11]‡ Barry
Ritholtz: Which US Companies have the Most Untaxed Foreign Income?; Corporate Management, Taxes and Policy,
15 April 2011, <http://www.ritholtz.com/blog/2011/04/what-us-companies-have-the-most-untaxed-foreign-income/
[ “Bitter Losses”; Development and
Cooperation Magazine, Deutsche Stiftung für Entwicklungsländer, Deutsche
Gesellschaft für Internationale Zusammenarbeit, 7 Aug.2010, <http://www.inwent.org/ez/articles/178169/index.en.shtml> .
[RivardK:89] Edward Rivard and
Kate Kaiser: “The Benefit of Quality IS”; Datamation,
Jan. 15, 1989. P. 53 (emphasizing the need to educate management, "especially
conservative anagement, on the importance of intangible benefits").[Schwarz:04}
[Roberts:01]
Richard
Roberts: Take your Partners;
Palgrave, 2001. Orion and the Euromarket. The Orion Story.
[Roberts:08] Richard Roberts: The
City, a Guide to London's Global Financial Center; The Economist, Bloomberg
Press, 2008. <and Megan Murphy? Much quoted by Shaxson, updated business count from
17,000 to 32,0000 on Oct.2002. [Hansard?] >
[Roberts:11] Justice John Roberts: FCC
et al. v. AT&T Inc. et al.; Supreme Court of the United States 1 March 2011.
FoIA case.
(app.G investigate)
[Romano:02] Carlo Romano: Advance
Tax Rulings and Principles of Law: Towards a European Tax Rulings System; International
Bureau of Fiscal Documentation (IBFD), Amsterdam, 2002.
[Romano:11] Andrew Romano: Maneuver allows Career Lawyer to Wield
Power in the Tax Division; Main Justice,
18 March 2011. Appointment of Mary L. Smith was
rejected by the House.
[Rodrick:98]
Dani Rodrik, Why do more open economies have bigger governments? Journal of
Political Economy, Oct.1998, 106 (5), 997-1032. Open economies , with more trade, (e.g., Austria,
Netherlands, Norway) have larger government sectors than closed economies,
which he attributes to their greater demand for public expenditures that
cushion the effects of globalization. Based on correlation.
[RoederKE:02] A. Roeder, H. K.Kroppen, &A. Eigelshoven: (2002). Chapter 24: Germany.
In Robert Feinschreiber (Ed.), Transfer pricing handbook (3rd
ed.). New York: John Wiley & Sons.
[RoessnerAFP]
David Roessner, Catherine P. Ailes, Irwin Feller, and Linda Parker: How Industry Benefits rom NSF’s Engineering
Research Centers”; p.40-44.
[Rosato:07]‡
Donna Rosato: File a squeaky clean 1040 tax form; Moey magazine, 23 Feb.2007. Random tax audits.
$345B
uncollected.
[Rose:13]
Charlie Rose: Interview with Bart Chilton, CFTC Commissioner; BBW, 6 May
2013.p.48.
Commisioner thinks a transaction fee would be hepful.
[Rosen:10] William Rosen: The Most Powerful Idea in
the World; Random House, 2010, ISBN 978-1-4000-6705-3.
[Rosenbaum:95]
David
E. Rosenbaum: Chairman Proposes Redefining Tax Code; New York Times, 7 Jun.1995. Bill Archer `Our Challenge is to do no less than pull the current income
tax code out by its roots’]
[
[RosenbergM:02]
Joel B. Rosenberg and Barbara N. McLennan: Technology, Licensing, and Economic
Issues in Transfer pricing; Chapter B in [Feinschreiber:01] , 2002 supplement.
Rosenberg:10] Dave
Rosenberg: “Oracle-Sun versus commodity hardware”; Cnet News, 31 Jan.2010. Acer 2 to 3%, Oracle-Sun
82%. routine 2% to 8%.
[Rosenbusch:08]
Nina Rosenbusch: “R&D Investments and the Long-Run Performance of IPO’S:
the Moderating Role Of Governance Structures (Summary)”; Frontiers
of Entrepreneurship Research, Vol.28, Issue 12, Chapter XII. Governance, 6 July 2008.
12] Steven Rosenthal: France Collects a finacial
non-trnsaction Tasx. Tax Policy Center, 8 Aug.2012.
[Ross:03] Philip E. Ross:
“5 Commandments, The rules engineers live by weren’t always set in stone”; IEEE Spectrum, 1 Dec.2003. Moore’s law if chip transistor growth, 1965; Rock’s law 1990: the cost of semiconductor
tools; Machrone’s law: thev PC price; Metcalfe’s Law: the value of anetorkk is
the number of users squared. 1993; 5:
Wirth’s (0r Reiser’s) Law: software is slowing faster than hardware is
accelerating, 1995.(goeves givith and Gates taketh away)o quote. Check
[Rossotti:98]‡ Charles O.
Rossotti: Statement; IRS Oversight Hrgs.
Before the Comm. on Finance, U.S. Sen. 201, S. Hrg. 105-598, 105th Cong. 2nd
Sess. , 28-30 Apr. & 1 May 1998.
[Rossotti:02]‡ Charles O. Rossotti: ‘‘Assessment of the IRS and
the Tax System, Report to the IRS Oversight Board’’; Doc 2002-21785, 2002 TNT
186-17, 20 Sep 2002, in [JCT:03, p.32,40]‡.
[Rossotti:05] Charles O. Rossotti: Many Unhappy Returns; Harvard Business School Press, 2005. Much honest information. Taxpayer bill-of-rights, 1988 no collection quotas p.14. revamping IRS, Ditricts p65, 166-173, LSMB formation p169-193, Unequal enforcement p268-176 `not adapted to modern business’. Complexity p245. Fractional settlements p246. Employee performance criteria p. 109-117, 158-163; Long aidit periods p.245,,Few agents trained p.247.Used as reference for tax advisores in Chap9 p253-258. Conformance p255. Balancing difficult audits p 263. Refer to Johnston NYT article 2002. working poor. Shelter risk & settements p277, funding of the IRS, part odf discretionary funding, p.278. IRS hands out benefiots as credits that `50% of the SSA, on 25% of the budger. p279. Staff size not changed since 2001
[Rostenkowski:84]
Dan Rostenkowski et al.: The Deficit Reduction Act of 1984 (DEFRA); US House of
Representatives H.R.4710, introduced 20 Oct 1983, became Public Law 98-369 18
July 1984.. includes USC Title 26 §367: Foreign Corporationd, Dec. 1984., used USC 936
(h)(3)(B) for the defintion of intangle property.
[RostenkowskiEa:86] Dan Rostenkowski et al.: Tax Reform Act of 1986,
Conference report, HR 3838; 22 Nov.1985.
Sponsor’s
summary. Introduces many changes to corporate taxation, including Subpart F in
Title IV. Addresses personal holding
companies. About 400 distinct provisons.
[RothEa:98] William V. Roth, jr. (chairman): IRS Restucturing and Reform Act of 1998,
Conference Report; US Congress, to accompany Bill H.R. 2676, Apr.1998.
[RothN:99]
William V. Roth,
jr. and, William
H. Nixon: The Power to Destroy; Atlantic Monthly Press., (1999). ISBN 0-87113-748-8. Leakage of tax information.
[Rottman:06]†
Joseph P. Rottman: "Successfully Outsourcing Embedded Software
Development"; IEEE Computer; Vol.39
no.1, Jan.2006, pp.55-61.
[Roux:97] David
Roux: Statement about software growth; 1997, Silver Lake Partners.
[RoyaltyStat:10]
database of royalty agreements with rates or fees and conditions. $4,500/year
for 100 downloads. <http://www.royaltystat.com/royaltystat.cfm.
[Rubin:10] Courtney
Rubin: Small Businesses fight Offshore Tax havens; Inc Magazine, 20 July 2010. Senator
Carl Levin, a Michigan Democrat, is backing the campaign,
officially called Business
and Investors Against Tax Abuse and to be launched
today.
[Rubin:11]
Richard Rubin: Deposit $1billion, get a massive tax break; Bloomberg Businessweek, 7 Nov.2011. Corporate taxrate 25%, discount of 95%
in foreign income, but existing overseas profits pay 5.25%, payable over 8
years, IP based income taxed at 15%, expt in taxhavesn (tax less than 10%) plus
penalties for IP income kept overseas.
[Rubin:12] Richard Rubin: ”Romney
Tax Cut Proposal Relies on Rapid Growth Paired with Missing Details”; Bloomberg Businessweek, 24 Feb.2012. Tax rates 28% reduced by 8% $-6,2Trillion foregone
revenue. Keep capital gains at 15%. No tax
on dividends for low-income (<2000K/year) No investment taxes ? from 2010
health care law. No AMT, no Estate tax Corporate tax 25% permanent R&D
credit. Depends on growth. But effect is less today [MankiwW:05] mankiw 2012 comment
on Romney bill: 30% recovery of corp. tax, 10% on labor tax reductions.
[Rubin:12B]
Ben Fox Rubin: Former Dow Chemical Scientist Gets Five Year in Prison; WSJ, 13
Jan 12. For stealing trade secrets to China.
[Rubin:12K]
Kenneth Rubin: Essential Scrum: A Practical
Guide to the Most Popular Agile Process ; ; Addison-Wesley, 2012.
[Rubin:12] Richard Rubin: ”Hidden Hnad:
Todd Grams’; Bloomberg Businessweek,
24 Jun.2013..
[RubinG:12] Richard Ruboin and Brendan Greeley: “If you don’t know him,
Your Accountant will; The Problem with Patching Up the Tax Code”; BBW, 15 Apr.2013, pp.24-26. Congressman
Dave Camp is working on a tax overhaul. .[Rubio:12] Marco
Rubio: Is the American World Order
Sustainable and Necessary in the 21st Century?; Transcript of talk at the
Brookings Institution, 25 April 2012. Yes, America must lead.
[RubinZ:11] Richard Rubin and Andrew Zajac: IRS Warns Busy Signals, Weaker Enforcement Will Follow
Cuts; Bloomberg Businessweek, 17 Oct
2011. IRS
budget request. Audits will reduce by 5% to 8%, loss $4B. current budget
12.1, increase requested 13.33. house 11.5, senate 11.7, 94,346. 10db30ps,xls.
Revenue agents: 14,588, Investigations:4,270, attorneys 1,610.
[Ruding:00]
Onno Ruding, Chair: ; EC Survey of 965 EU
companies. Median revenue of all was £38.5, and £281,5 for multinationals. Effective
EU tax rate for foreign-source income is 11.2%. see [Devereux:92] .
Article I of the U.S. Constitution grants Congress the
power to appropriate funds from the Treasury, pay the obligations of and raise
revenue for the federal government, and publish statements and accounts of all
financial transactions. By law, Congress is also obligated to write a budget
representing its plan to carry out these transactions in the forthcoming fiscal
years. While the President is required to propose his administration’s budget
requests for Congress’s consideration, Congress alone is responsible for
writing the laws that raise revenues, appropriate funds, and prioritize
taxpayer dollars within an overall federal budget.
[Rykers:09] Darren Rykers: A Critical Analysis of how
Double Tax Agreements can facilitate Fiscal Avoidance and Evasion; The
Taxpayer and the Lotus, 17 Nov.2009. <from vaibhav, get reference from Internet, chap 8,
tax treaties> Treaty shopping.. have “I am very passionate about further
education and have completed the CPA program, an MBA from New York Institute of
Technology and am currently undertaking a Master of International Taxation at
the University of New South Wales school of Law. In addition I have been
lecturing in Accounting and Taxation at a number of Australian universities
based in Singapore. I am a volunteer with CPA Australia assisting in the
mentoring of up and coming CPA’s.”
[RyleGHHCC:13] Gerard Ryle, Marina Walker
Guevara, Michael Hudson, Nicky Hager, Duncan Campbell and Stefan Candea: Secret
Files expose Offshore’s Global Impact; Huffingtom Post. 3 Apr.2013.
[SAB114:11] SEC: Staff Accounting Bulletin 114; U.S. Securities and Exchange Commission, Division of
Corporate Finance, 28 March 2011 .
staff: 20%, multiplied for lower levels. . http://www.sec.gov/interps/account/sab114.pdf.
[Sachs:05] Jeffrey Sachs: The End of
Poverty: Economic Possibilities for Our Time; Penguin Press, 2005. Needs in India,
ability to change things. Nothing on taxhavens etc. have.
[Sadowski1:11]
Robert Sadowski: “A Cash Buildup and Business Investment”; Federal Reserve Bank of Cleveland:
Economic Trends, Jan.10, 2011, http://www.clevelandfed.org/research/trends/2011/0111/01regact.cfm
.
the
primary reasons firms are not investing more are lack of demand and uncertainty
about the health of the economy
[Sah:83] Raaj Kumar Sah: How much
redistribution is possible through commodity taxation?; Journal of Public
Economics, Feb.1983, 20 (1), 89-101.
[Sahadi:11] Jeanne Sahadi: “Corporate tax reform: Talk grows louder”; CNNMoney, 14 Jan. 2011.
[Sahadi:12] Jeanne Sahadi: “Business Tax breaks booted from Payroll Deal”; CNNMoney, 17 Feb. 2012.
[Saini:11]
Angela Saini: A formula for Justice; The Manchester Guardian, 2 Oct 2011. bayes rule.
Comment: A`well
funded prosecution or defence will always be able to buy expert opinion.
Justice should be better than this. Indeed if we are to have any confidence in
our system of justice it HAS to be better than this. The Court should provide
an unbiased expert.
[SaintMatthew: 0042] Honoring the Patron Saint of
Accountants on All Saints' Day; <http://www.accountingweb.com/item/102756. Memorial
Day / Feast Day: Sep.21st.
[Saitto:10] Serena Saitto: “U.S. tech firms shop abroad to avoid
taxes”; Bloomberg Businessweek, 6
Sep.2010, pp.31-32. Quotes CISCO.
[Sakey:12]‡ Matt Sakey: Assemblageddon; Digital Manufacturing Report, 1
Feb.2012. Scope of manufacturing.
[Salmon:12] Felix Salmon: How to reduce the
deductibility of intrest payments; 23 Feb.2012. Refers to
[BurnhamO:05] .
[Sample:12]‡ Bill Sample: Statement to Congress; Corporate Vice President for Worldwide Tax, Microsoft Corporation, Permanent Subcommittee on Investigations, U.S. Congress, 20 Sep.2012. Has 54,000 emp
[Samuelson:83]† Paul A. Samuelson:
Foundations of economic analysis.
Cambridge; Harvard University Press, 1983.
[Sanchirico:12] Chris William Sanchirico:
Optimal Tax Policy and Symmetries of Ignorance; Wharton School, 2012,
SSRN-id1856123. What should be taxed? labor, capital,
High-level simulation. Cocludes
that labor-earnings only taxation, as proposed by [AtkinsonS:76] is not proably optimal. What happens to
generated IP? Very extensive foot notes.
[Sanders:81]
Hyman Sanders and Treasury Staff: A review of the Accuracy of Treasury Revenue
Forecasts, 1963-1978; CBO, , Alice M.
Rivlin , Feb.1981, <http://www.cbo.gov/ftpdocs/53xx/doc5347/doc08-Entire.pdfl>.
[Sanderson:13]
Rachel Sanderson: “Fiat Industrial to move tax home to UK”; Financial Times; 21 May 2013. Italy’s tax is high
nad most operationS, and CaseNewHolland, are in the UK, But is that all?
[SanJuan:11] Eric A. San
Juan: From Tax Collector to Fiscal Automaton: Demographic History of Federal
Income Tax Administration, 1913-2011; Volume 2 of [Olson:11]‡. Excellent history.
1953 53,463 employess., population 163M 33B indid income tax, 69.9B total .
1954 tax expenditure – child care deduictibel for single parents. AMT 1969.
(TRA 69). TRA 75 disbursement. TRA 76 Privacy law first 1976, after Watergate.
1985 pop. 102M, collect 742B individual 397B. 92,792 employees, level staffing. IRS administering social benefits programs, disbursing funds.
[SantosRodriguesPC:13] Santos-Rodrigues Helena,
Guiomar Pereira- Rodrigues, and Desire
Cranfield: Human Capital and Financial Results: Case Study; IPVC, Portugal and
University of Southampton, UK, 5th
European Conference on Intelectual Capital, Bilbao, April 2013.
[Sargent:87]
Thomas J. Sargent: Macroeconmic Theory; Harvard Univ. Press, 1987. have
[Sargent:05]
John Sargent; Office of Technology Assessment, 2005. US IT employment
3.170M.Via ACM globalization report. <but OTA was closed in 1995>
[Sassen:12]
Saskia Sassen: "Digital Formations of the Powerful and Powerless";
ICSE 2012. “who gave a fascinating keynote”, At
Columbia University. On slideshare
China State Administration of Taxation, Circular Guoshuifa 2009 no.2, 8 Jan. 2009; Obtainable from www.kpmg.com/cn/en/whatwedo/tax/global-transfer-pricing-services/pages/china-transfer-pricing-regulations.aspx.
[SaterianoB:11] Adam Sateriano and Peter Burrows: Apple’s Supply-Chain
Secret: Hoard lasers; Bloomberg
Businessweek, 7 Nov.2011, pp.35-37. High investment
contributes to Apple’s margin 40%. [ACM]
[Saunders:11]
Laura Saunders: “Rich Are Targeted in IRS Audit Offensive”; Wall Street Journal, 4 April 2011. The biggest jumps came at the top of the income
ladder. About 18% of Americans earning at least $10 million were audited in
fiscal 2010, up from 11% in fiscal 2009, according to the IRS. For those
earning $500,000 to $1 million, the audit rate rose to 3.4% from 2.8%.The
biggest jumps came at the top of the income ladder. About 18% of Americans
earning at least $10 million were audited in fiscal 2010, up from 11% in fiscal
2009, according to the IRS. For those earning $500,000 to $1 million, the audit
rate rose to 3.4% from 2.8%.
[Savodnik:13]‡
Peter Savodnik: “Gimme Shelter”; Blomberg
Business Week, 21 Jan.2013, pp.66.67. Examples of some of 70 taxhavens sheltering
$21xto $32T: Delaware, Cayman Islands, Belize, Jersey, Norway, Cyprus, Dubai..
[Saxton:99] Jim Saxton: Tax Expenditures: A Review and Analysis; Joint Economic Committee, United States Congress, Aug.1999.
[Schachter:09]
Harvey Schachter: Adapting for success on foreign shores; The Global Mail, Nov.2009.
[Schaeffer:04]‡
Bernie Schaeffer: Dynamic Market Opportunities; PRNnewswire, 17 Dec.2004. “2004 certainly seems to be the `Year of the
merger’.. with over 9800 deals concluded so far. The combined total is $789M, a
43% surge over the 552B last year”. Attached to Johnston:05
[SchanfeinEa:10] M. Schanfein, F.
Gouveia, C. Crawford, C. Pickett, and J. Jay: The International Safeguards
Technology Base: How is the Patient Doing? An Exploration of Effective Metrics;
Idaho national labs (INL), doc. INMM 2010,
July 2010 . A definition
of technology base.
[Schapiro:09]
Mary L.
Schapiro: Address to Practising Law Institute's "SEC Speaks in 2009"
Program; U.S. Securities and Exchange Commission, Ronald Reagan International
Trade Center, Washington, D.C., Feb.6, 2009. The SEC's budget
in 1994 was $260 million, less than one-third of what it is today ($906
million). U.S. mutual fund assets, which totaled $2 trillion in 1994, have
grown to nearly $10 trillion today. = .01%
[Scheer:10] Robert Scheer: The Great American Stickup: How Reagan Republicans and
Clinton Democrats Enriched Wall Street While Mugging Main Street ; Nation Books, 2010.
[Scheier:11] Bruce Scheier: Do Corporations have a Right to Privacy?;
Scheier on Security, 20 Jan.2011. <www.schneier.com/blog/archives/2011/01/do_corporations.html>
[SchilitP:10]
Howard
Mark Schilit and Jeremy Perler: How to Detect
Accounting Gimmicks & Fraud in Financial Reports, 3rd ed.; McGraw-Hill,
2010. Financial Shenanigans
[Schlosser:03]
Eric Schlosser: Reefer Madness: Sex, Drugs, and Cheap Labor in the American
Black Market; Houghton Mifflin Harcourt, 2003. The size of the underground
economy, drug illegal labor, and porn is
over $1T.
[Schlunk:00] Herwig J. Schlunk: The Zen of Corporate Capital
Structure Neutrality; Michigan Law Review,
Vol.99 no.2, Nov.2000, pp.410-451.
[Schlunk:04] Herwig J. Schlunk: Double Taxation: The Unappreciated Ideal;
Tax Notes, Vol.102 No.7, 16
Feb.2004.
[Schlunk:05] Herwig J.
Schlunk: A Minimalist Approach to Corporate Income Taxation; NNew York
University Law and Economics Working Papers. Paper 6, , 3 Feb.2005; Vanderbilt Univ. Law School, Law and Economics, working paper 05-06, 3
Feb.2005. tax internally created intangible
income (organic). Double taxation is appropriate.
[Schlunk:06] Herwig
J. Schlunk: A Minimalist Approach to Corporate Income Taxation; SMU Law Review, Vol.59 no.2, Spring2006, ,
pp.785-834; New York University Law and Economics Working Papers no.6, 3 Feb.2005; Vanderbilt Univ. Law School, Law and Economics, working paper 05-06, 3
Feb.2005. tax internally created intangible
income (organic). Double taxation is appropriate.
[Schlunk:06R]
Herwig J. Schlunk: Rationalizing Reorganizations and Other Corporate
Acquisitions; Vanderbilt Univ. Law School, law and Economics, working paper
06-24, 1 Dec.2006.
[Schmidt:11] Anatoly B. Schmidt: Financial Markets and Trading: An Introduction to Market Microstructure
and Trading Strategies; Wiley, 2011. On Kindle
[Schmidt:12] Robert Schmidt: Meet the Man Who Is Defending the 1%; Bloomberg Businessweek, 20 Feb.2012,
p.32. Carried
interest issue.
[Schmookler:62]
Jacob Schmookler: "Economic Sources of Inventive Activity“; The Journal of Economic History, Cambridge University Press, vol.22 no.1, pp.1-20,
March , 1962. [Schnepper:10]‡ Jeff A. Schnepper: How to pay Zero
taxes; McGrawHill-NewsMax, 2011.
[SchoenK:12]‡ Wolfgang Schön and Konrad A Kai (eds): Fundamentals of
International Transfer Pricing in Law and economics; Springer MPI studies in
Tax Law and Public Finanace, Vol.1, 2012.
[Scholte:97]
J. A. Scholte: Global capitalism and the state; International Affairs,
Vol.73. no.V, pp.427-452.
[Schreiber:12]‡
Ulrich Schreiber: International Company
Taxation, An Introduction to the Legal and Economic Principles; Springer,
2012. All the formulas you’d want, little
semantcs
[SchumanO:93]
David Schuman and Dick W. Olufs III: Public
Administration in the United States; Lexington, 1993,2nd Edition, D. C. Heath and Company. ..discuss several
principles that can guide the choice of who should pay taxes. These
principles range from benefits received from government services, ability to
pay as measured by their income, to the concept of tax policies that
change people's economic behavior (“sin” taxes). Corporations, as
beneficiaries of public goods, are, therefore, required to pay for the services
the government provides. P., 414-420).
[Schumpeter:12]
Joseph Alois Schumpeter: The
Theory of Economic Development, an inquiry into profits, capital, credit,
interest, and the business cycle; 1912, translated from the German Theorie der
wirtschaftlichen Entwickling, 1911, by Redvers Opie; Harvard
University, 1934; Oxford
University Press, 1961; reprinted by
Transaction Publishers, 1983. All goods have their origin in labor or nature. Obviously
ignores intelectual output. Demand for new goods, profit, and value, ignoring
the cost of production – non-routine profits. Effect of transport costs --
before containerization.
[Schuster:11] Steve Schuster: “Samuel Maruca: Strategic Case
Selection Key Aspect of Transfer Pricing Practice; BNA Daily Tax Report, 29 July 2011. Report on speech by Sam Marucca.
[SchuylerE:13] Michael Schuyler and Stephen
Entin: The Economics of the Blank Slate: Estimating the Effects of Eliminating
Major Tax Expenditures and Cutting Tax Rates; Tax Foundation Fiscal Fact No.378,
26 July 2013, http://taxfoundation.org/article/economics-blank-slate-estimating-effects-eliminating-major-taxexpenditures-and-cutting-tax-rates.
[Schwartz:13] Nelson
D. Schwartz: ”Web of Tax Shelters Saved
Apple Billions. Inquiry Finds”; The New York Times, 20 May 2013.
$74B
offshore. Ireland tax 1% on $22B income [ACM]
[Schwarcz:04] Steven L. Schwarcz: “Rethinking the Discourse Paradigm
in a World of Complexity”; Univ. of Illinois Law Review, Vol.2004, Duke
University, 2004. Enron
[Schweizer:13E] Peter Schweizer: Extortion: How Politicians Extract yopur Money, Buy Votes, and Line Their own
Pockets Racket; Houghton Mifflin
Harcourt, Oct.2013. A
valid diatribe, accuses Obama as well.
[Schweizer:13P] Peter Schweizer:
“Politician’s Extortion Racket”; New York
Times, 21 Oct.2013. Pointer
provided by Jake Feldman. Comapaipaign
contributions fror corporate tax benefits. Milker bills and double milker bills
[ACM]
[Schwinn:98]
E. Schwinn: “No Easy Solutions seen for Problems Arising from the Use of Secret
Comparables”; Tax Management Transfer Pricing Report no.6, 22 April 1998,
p.907-911.
[Scott:11] Robert E. Scott: Growing U.S. trade
deficit with China cost 2.8 million jobs between 2001 and 2010; Economic Policy
Institute, 20 Sep.2011.
[Scott:13] Robert E. Scott: Trading Away the Muafacturing
Advantage: China trade drives down U.S. wages and benefits and eliminates good
jobs for U.S. workers; Economic Policy Institute, 30 Sep.2013. Detailed data by worker sector. Ignores US IP
contribution in Chines exports.
[SEC:03] U.S. Securities and Exchange Commission: Strengthening
the Commission's Requirements Regarding Auditor Independence; Supporting USC
Title 15, Chapter 2 , and regulations as Title II of SOX, Title 17 CFR PARTS §210, §240, §249 and §274, final rule, 27 March 2003,
<http://www.sec.gov/rules/final/33-8183.htm>
[SEC:10B]‡
U.S. Securities and Exchange Commission: Spotlight on Stock Options Backdating;
<http://www.sec.gov/spotlight/optionsbackdating.htm , updated 16 July 2010.
[SEC:10C]‡
U.S. Securities and Exchange Commission: Corporate Reports, How to Get;
<http://www.sec.gov/answers/companyinfo.htm, updated 23 July 2010.
[SEC:11]‡ U.S. Securities and Exchange Commission:
Financial Reporting Manual; U.S. Securities and Exchange Commission, Division
of Corporate Finance, 1 July 2011, Reference 17 CFR part 211.
[SeshasaiG:06]
Satwik. Seshasai and Amar Gupta: The
24-Hour Knowledge Factory Paradigm; MIT working paper ESD-WP-2006-16,.
[SeshasaiG:09] Satwik Seshasai and Amar Gupta: ”The 24-hour Knowledge Factory”; ACM Transactions on Internet Technology,
Aug.2009.
[Seymour:12] Jim
Seymour et al.:4G Mobile Broadband Evolution:3GPP release 10 and Beyond,
HSPA+_, SAE/LTE and LTE-Advanced; Jan.2012 update, 210pp.4gamericas.org/
[SGO:98]
Senior German Tax Officials: Transfer
Pricing: German Positions Shifting on Profit Split And Comparable Profit
Methods; International Tax review, 1
Oct 1998. Senior German tax officials responsible
for Germany's international tax policies have consistently stated in public
that comparable profit methods and transactional net margin methods will not be
accepted by the German tax authorities, and that profit splits are only
acceptable in rare instances as a method of last resort. They have also
frequently expressed their opposition to US-style economic analysis and voiced
serious reservations concerning Advance Pricing Agreements (APAs). The rapid
globalization of the world's economies and the trans-nationalization of most
major..
[Shakespeare:1597] William Shakespeare: Romeo and Juliet; first quarto edition, 1597.
[Shah:09]
Anup Shah: Tax havens, undermining democracy; Global issues, 12 July 2009.
[ShahS:11]
Vishal Shah and Smit Sheth: Getting a handle on the Mauritius Tax Treaty;
Reuters, 11 July 2011
[ShaneB:11]
Scott Shane and Penn Bullock: “Group in U.S. Saw Qaddafi as Big Payday; The New York Times, 18 Nov.2011. It takes $10M to
get anything done in Washington.
[Shapiro:08]
Glen Shapiro: US Treasury Praises IoM For Role In Fight Against Financial
Crime; Law and Tax News, 18 June
2008. William
F. Baity - Deputy Director of FinCen, the Financial Crimes Enforcement Network
says Isle of Man cooperates.
[Sharman:06]
Jason C.
Sharman: Havens in a Storm: The Struggle for Global Tax Regulation; Cornell
Univ. Press, 2006.
[Sharpe:85] William F. Sharpe: Investments; Prentice-Hall, 1985.
Capital asset Pricing Model (CAPM). Expected Rate of Return on Equity Capital RREC =
RiskFreeRate + beta * (BroadStockPortfolioReturn - RiskFreeRate). In 2000 the RiskFreeRate based on U.S.Treasury
Bonds was 6.13%. The BroadStockPortfolioReturn in 2000 was 11.1%, Beta for SW
was 1.31, making RREC= 12.68. Per PWC a small company premium, to be added for
startups is 4.4% giving 17%. Without the
small-business correction the beta would be 2.174 versus the broad portfolio,
less for better matching portfolio.
|
[Shaviro:11] Daniel Shaviro: "The
Rising Tax-Electivity of U.S. Corporate Residence"; Tax
law Review, Vol.64 no.3 , Spring 2011,p.333; NYU Law and Economics
Research Paper No.10-45, 2010, 66 pp., <www.law.nyu.edu/ecm_dlv1/groups/public/@nyu_law_website__alumni/documents/documents/ecm_pro_066815.pdf>. [Shaw:06] Helen Shaw: “Must Reading for IRS agents”; CFO magazine, 31 May.2006. New FASB
SEC rule gives more information to IRS `More likely than not’ rule [Shaw:06C]
Helen Shaw: “Software Capitalization Clouds Comparisons”; CFO.com, 26 May
2006. “Although
many companies expense their software development costs, according to a new
study, differences in accounting approaches can give ''the impression that
those that are capitalizing are doing better financially.'' Cites [Mulford:06]
. [Shaw:06E] Helen Shaw: “Execs:
Broken Tax System hurts Business”; CFO
magazine, 21 Sep.2006. Quotes Rossotti at Senate hearing.. 2.9 changes per working day.
Kimberly-Clark’s 2005 tax retrun was 3,300 pages. Nom specific detail,
clean slate wanted. . [Shaw:06N] Helen Shaw: “New
Transfer pricing Regs a Catch-22”; CFO
magazine, 14 Aug.2006. New: Contingent Servoice Agreements,.for R&D. Requires arm’s-length. [Shay:07] Stephen E. Shay
(Partner, Ropes & Gray): Hearing on Banking Secrecy Practices and Wealthy
American Taxpayers; Subcomm. on Select
Revenue Measures of the H. Comm. on Ways and Means, 111th Cong. 3–4 , 2009. Discussing the
various tax gap estimates. 2001 measure did not include offshore [Shulman:08]
[Shay:11] Stephen E. Shay: Jobs, Deficit Reduction Revenues and
Fundamental Tax Reform; Tax Notes Vol.133 no.2, 10 Oct.2011, pp.213-216. Advocates a
mixed policy. Politically wise to be against taxation.. many tax breaks not labeled as tax
expenditures. No specific recommnedations. [Shay:12] Stephen
E. Shay: Testimony to Congress; Permanent
Subcommittee on Investigations, U.S. Congress, 20 Sep.2012. Harvard Law School, Retained income 8% of
corporate income is deferred. Data on Ireland MS consol 69.9B 17,5%
tax 90,000 emplu, offshore 55.5% earnings $15B – 4% tax, 1900 employees. $8M/employess vs
312 for Ms employees overall. Not consistent with common sense understanding.
Offshore is a firewall only. 2009 guidance to
subsidiary – should be independent subsidiaries, seems to be ignored. Staes
effective US rate is 27%. Multiple layers of valuation issues. Only
successful IP gets transferred. Accounting does ot match tax and intangible
value. Anti-abuse rules (956) arr drafted to narrowly, and their intent can
be easily subverted. “Prior to my current
position, I was the Deputy Assistant Secretary for International Tax Affairs
at the Department of the Treasury. Before my most recent government service,
I was a tax partner at Ropes & Gray LLP for 22 years specializing in U.S.
international income taxation before retiring to serve in government in 2009.
I have provided a copy of my biography to the Subcommittee. I occasionally
consult for Ropes & Gray LLP on mutually agreed projects. 3 I first served in the U.S. Treasury Department’s Office of
Tax Policy from 1982 to 1987. I was actively involved in the development
through 1984 of the Reagan Administration’s international tax reform
proposals and the legislative consideration of the proposals through signing
of the legislation on October 22, 1986. The process took almost three years
in total”. [Shaxson:11]
Nicholas Shaxson: Treasure
Islands, Tax Havens and the Men Who Stole the World; The Bodley Head,
London, 2011. Offshore sites and tax havens, including the US to hide and profit
from corruption. Focus on personalities. Africa. Less well referenced than it
appears. <diatribe> also “the tax haven in the heart of Britain; New Statesman, 11 Feb.2011.AIG in the
City p.248. Lehman’s repo as well p.249.. [Sheppard:04] Hale E. Sheppard:
“Reduced Tax Rates on Foreign Dividends Under JGTRRA: Ambiguities and
Opportunities”; J. Int’l Tax’n,
July 2004, at 14, 16-17. Sheppard:12O] Lee A.
Sheppard: “Megacoorps Are Not Overtaxed”; Forbes,
17 Apr.2012. Arghues nersus [Helman;12] of Forbes , 16 Apr.2012a, who wrote that LIFO and Oil examptions should remain. Tax Analysts. Sheppard:12R] Lee A.
Sheppard: “Mitt Romney Tax Clarifications”; Forbes, 11 Sep.2012. Refers to
13Aug.2012 report : Your Mitt Romney Tax issues Cheast Sheet’; Tax Analysts. [SheppardS:08] Lee A. Sheppard and Martin A.
Sullivan: “Repatriation Aid for the Financial Crisis?”; Tax Notes, 5 Jan.2008.
profit
multinationals keep offshore with the intention of maximizing tax advantages;
between 2003 and 2007, the annual increase in this measure doubled, from $60
billion to $122 billion. SheppardS:09] Lee A.
Sheppard and Martin A. Sullivan: “Multinationals Accumulate to Repatriate”; Tax Notes, 19
Jan.2009. ..[ACM]. [Sherer:65]
application to issue lag 3.5 years. For patents [Shierholz:11] Heidi Shierholz:
No jobs for more than three out of four unemployed workers; EPI News ,
Jan.11, 2011. [ShimSD:10] Jae K. Shim, Joel G. Siegel, and Nick Dauber: 2009-2010, Corporate Controller's Handbook of
Financial Management; CCH-Wolters, 2010. Have [Shiner:12]
Keegan Shiner: The Corporate Tax
Evasion Task Force; Community Tax Relief, 21 March 2012. http://www.treas.gov/tigta/iereports/2009reports/2009IER001fr.html. :08] Douglas H. Shulman: Subpart F. Imbalance of domestiv
corporations. :09]‡ Douglas H. Shulman: . |
|
[Shulman:10C]‡ Douglas H. Shulman: Prepared Remarks
of Commissioner of Internal Revenue to New York State Bar Association
Taxation Section Annual Meeting in New York City; IRS, Jan. 26, 2010,
<http://www.irs.gov/newsroom/article/0,,id=218705,00.html>. Voluntary disclosurte – amnesty Transfer pricing
handling needs change. Need more experts. Reach out to corporate board
directors. Transparency, Uncertain tax positions [Shulman:10O]
Douglas H. Shulman: Prepared
Remarks of Commissioner of Internal Revenue before the OECD/BIAC; 8 June
2010, Washington, D.C., www.oecd.org/document/16/0,3746,en_2649_33749_45425296_1_1_1_1,00.html. |
FATCA provides IRS with the tools we need to crack
down on Americans hiding assets overseas. First, it increases information
reporting by U.S. taxpayers holding financial assets outside the United States
and imposes stiff penalties for failure to comply. It expands due diligence
standards, so that we have a better line of sight to U.S. beneficial owners of
accounts. It also ramps up the stakes for foreign financial institutions
that will have to agree to disclose U.S. investors to the IRS or feel the pain
of a substantial new withholding tax on U.S. income and gains. The mere enactment
of FATCA should prompt preparers and advisors to expand their due diligence
regarding offshore account issues, including, but not limited to income tax
reporting. Overall, FATCA makes the world a much riskier place for US taxpayers
still trying to hide their money anywhere around the world.
[Shulman:10R] Douglas H. Shulman: IRS Realigns and Renames Large
Business Division, Enhances Focus on International Tax Administration; IRS
IR-2010-08, 4 Aug.2010 . LB&I will add LMSB’s 875 employees to the existing
international staff of 600. Among the responsibilities of the new entity are: identifying and addressing emerging
compliance issues; decreasing instances of tax evasion through foreign
holdings; increasing
IRS specialization in international issues; overseeing implementation of the
Foreign Accounting Tax Compliance Act (FATCA); and revising tax treaties and tax
information exchange agreements., LB&I will serve the
same segment of U.S. taxpayers, which include corporations, subchapter S corporations
and partnerships with assets greater than $10 million and certain high-wealth
individuals.
[SimanjuntakT:11]
Destrina Grace Simanjuntak and Raymond R. Tjandrawinata,:” Impact of
Profitability, R&D Intensity, and Cash Flow on R&D Expenditure in Pharmaceutical
Companies”; (April 29, 2011). Available
at SSRN: http://ssrn.com/abstract=1824267 or
http://dx.doi.org/10.2139/ssrn.1824267
{SimenskyB:94]
Melvin Simensky and Lanning G. Bryer: The
New Role of Intellectual Property in Commercial Transactions; John Wiley
& Sons, 1994.
[Simmons:38]‡ Henry
Simmons . Classic work on individual income tax.
[Simms:11] James Simms: “Japan Needs to Muffle That Hollow
Sound”, Wall Street Journal, 9 Dec
2011.
Hollowing out: Japan offshores 33% of its manufacturing, expected to rise to
39% by FY2015.
[Simpson:02]‡ Glenn
R. Simpson: "Enjoy, A New Twist in Tax Avoidance: Firms Send Best Ideas
Abroad"; Wall Street Journal, 24
June 2002. Front Page <IRS/Guidance/WSJ-International Transfer Pricing>
[Simpson:02a] Glenn
R. Simpson: "Glaxo in Major Battle With IRS Over Taxes on Years of U.S.
Sales"; Wall Street Journal, 2114 June 2002, Page A1. Cited by Durst,
magnitude and tedium of trials. $5B in taxes and interest are involved Glaxo.
[Simpson:05]‡ Glenn R. Simpson:
"Irish Subsidiary Lets Microsoft Slash Taxes in U.S. and Europe"; The Wall Street Journal, 7 Nov.2005, p.
A1. <
References for Guidance /Simpson05>.[ACM].
[Singhvi:10]
: Aashish Singhvi: Global Semiconductor Alliance Chain Practices Report; Global
Semiconductor Alliance (GSA), 2010.
[Sinclair:35] Upton Sinclair: I, Candidate for Governor: And How I Got Licked ; 1935; University of California Press, 1994. ISBN 0-520-08198-6, p. 109: “It is difficult to get a
man to understand something, when his salary depends upon his not understanding
it” (applies to IP valuation) quoted by Gillian Tett in [Byrnes:12]
[Slaughter:08] Matthew Slaughter, Dartmouth Univ.: The
Immigrant gap; Wall street Journal, 1
April 2008. Cited
by [Wessel:11] . 2004 study, for 1991-2004 2 US jobs for every foreign job,
later about equal 3.8M versus 3.6M. 2000-2005 2.1M jobs eliminated, 784,000
foreign jobs added. [Bureau of Economic analysis] In 2005 9M foreign
employees. Also Prof. Clausing Reed
college. Also "Economic Insecurity and the Globalization of Production”;
with Kenneth F. Scheve, American Journal of Political Science, Vol.48 no.4,
2004. Globalization and the Perceptions of American Workers, with Kenneth F.
Scheve, Washington , DC: Institute for International Economics, 2001.
[SlavinK:06]‡
Nathan S. Slavin and Abu Ryan
Khan: ”In-Process R&D in Business Acquisitions
More
Disclosure Needed for Transparency and Comparability”; The CPA Journal, August, 2006. Changes in handling of IPR&D handling are due. Watch
FASB. SFAS 141 and 142. 28% discount rate used. Comment on Levitt (SEC) 1998
talk.
[Slemrod:88]
Joel B. Slemrod: Progressive taxes; The
Concise Encyclopedia of Economics, Library of Economics and Liberty, <http://www.econlib.org/library/Enc1/ProgressiveTaxes.html>. The
statutory tax rates misrepresent true progressivity for three reasons 1.
Taxbase 2. Salaries to compensate,
burden. 3. income taxes are only 25% share
[Slemrod:88] Joel B. Slemrod: “On the High-Income Laffer Curve”; J.
Slemrod (ed.), Tax Progressivity and
Income Inequality, Cambridge University Press, 1994, pp.177-210.
[Slemrod:95] Joel B. Slemrod: “Professional
Opinions About Tax Policy, 1994
and 1934” ; National Tax Journal,
March 1995, Vol.85 no.2, pp.121-147; also appears in [Slemrod:99] . <check> Survey based“it is
administratively not feasible to tax on a residence basis, (so one has to tax
on a source basis). Less emphasis on redistribution of waerlth? 28% for a flat
tax, 36 for value added tax vs income tax.
70% for taxation of inflation adjusted. capital gains as ordinary income
(65%).
[Slemrod:96] Joel B. Slemrod (ed.): The Taxation of Multinational Corporations;
Kluwer Academic Publishers, 1996. New edition in 2011, but paper topics are
similar. Contains 6 papers: [AltschulerM:96]; [BlumenthalS:96];
Collins and Shakelford: Corporate Domicile and Effective Tax rates; Devereaux
and Freemn: Thje Impact of Tax on Foreign Direct Investment; Leamer: What Do We
Know About the Impact of Offshore Investment on the US Econmy; Free Trade
Taxation and Protectionist taxation.. Had from Stanford Library.
[Slemrod:98]‡ Joel B. Slemrod: “On Voluntary Compliance,
Voluntary Taxes, and Social Capital”; National Tax Journal, 1998, vol.51, pp.485-491.
[Slemrod:99] Joel B. Slemrod (ed.): Tax Policy in the Real World; Cambridge Univ.
Press, 1999. Have. About 20 papers
[SlemrodB:08]
Joel
B. Slemrod and Jon Bakija: Taxing
Ourselves, A Citizen’s Guide to the Debate over Taxes, 4th
edition; MIT Press, first edition 1999. Have. Excellent, but nothing on IP and taxhavens
[SlemrodS:93]
[xls/irs]‡
[SlemrodY:02]‡ Joel Slemrod and Shlomo
Yitzhaki: “Tax Avoidance, Evasion, and Administration”; Chapter 22 in A.
Auerbach and M. Feldstein (eds.), Handbook of Public Economics, Vol.3,
Elsevier Science B.V.2002. Model-based analysis. Considers developing countries. IRS
costs 0.6% of revenue. Risk of being challenged (Chap.8)
[SlemrodW:09]
Joel
Slemrod, and John D. Wilson: “Tax Competition with Parasitic Tax Havens”; Journal of Public Economics, Vol.93 no.11–12,
2009, pp.1261–70. Draft 2006.
[Slim:12] Richard Slim: Patent, Copyright & Trademark,
12th edition; NOLO puvlishing, March 2012.
[Small:03] Garrick
Small: The Dimensions of Human Action and Property; Pacific Rim Property Research Journal Vol.9 No.3 Dec.2003; also at
www.rics-foundation.org/publish/download.aspx?did=3125
.
[Smil:00. ] Vaclav Smil: Feeding the World: A Challenge for the Twenty-First Century ;
MIT Press, 2000.
[Smil:04] Vaclav Smil:
Fritz Haber, Carl Bosch, and the Transformation of World Food Production; MIT
Press, 2004. ISBN 0262693135. Focus on fertilizer.
[Smith:1759] Adam
Smith: The Theory of Moral Sentiments; Uplifting
Publications, Amazon Kindle edition, 2010.
On
Kindle. Deals with “sympathy”, “propriety”, “happiness”, “compassion”, “To what
purpose is all the toil and bustle of this world? What is the end of avarice
and ambition, the pursuit of wealth, of power, and preeminence”
[Smith:1776] Adam
Smith: The Wealth of Nations; Amazon
Kindle edition, 2009. On Kindle “The directors of such [joint-stock] companies,
... being the managers of other people’s money that their own, it cannot well
be expected that they should watch over it with the same anxious vigilance with
which the partners in a private copartnery frequently watch over their own”
[Smith:62] Dan Throop Smith: Depreciation, Obsolescence, and Depletion;
Harvard University, 1962.
[Smith:97]
Gordon V. Smith: Trademark Valuations, 3rd; Wiley 1997. Book is also
referred as "Valuation' in Amazon. In Great Britain, since 1981 `Companies
Act', trademark values can be placed on the books. But the U.K. Accounting
Standards Committee (ASC) disagreed subsequently, but with amortization they
can appear. Internally generated trademarks are only to be put on the books if
they have an ascertainable value [SmithP:00, p 92] .
[Smith:08] Vernon L.
Smith: Rationality
in Economics: Constructivist and Ecological Forms; Cambridge Univeristy Press,
2008. This guide is about centrist economics but you can
easily be a libertarian. The Nobel Prize winning economist has created and
absorbed all of these modern advances in economics and makes the case for
markets in a way that the Friedrich Hayek would love. Not very relevant as I
glanced through it <gio>.
[Smith:11]
Judge William E. Smith:
Uniloc v. Microsoft; United States
District Court for the District of Rhode Island
in Case No.03-CV-0440, 4 Jan.2011. Royalty 25% rule-of-thumb
invalidated.
[SmithEa:12] Patrick
Smith, Jason Johns, David Wong, Mary Lee, Chris Bard, and Hoon Lee: The
Research Credit and Deduction for Passthrough Entities; The Tax Adviser, AICPA, 1 May 2012.
[SmithP:94]
Gordon Smith and Russell Parr; Valuation of Intellectual Property and
Intellectual assets; Wiley, 1994, 1989. <at Joaquin
[SmithP:00] Gordon Smith and Russell Parr; Valuation of Intellectual Property and Intangible Assets; 3rd edition; Wiley 2000. Has a 2004 cumulative supplement ISBN-13: 978-0471464693
[SmithP:05]†
Gordon Smith and Russell Parr: Intellectual Property, 4th edition; Wiley 2005.
Shirley has it, I have it, and the 2008 supplement. See [Carson:08] . On page 35: "A
new term "Intellectual Capital" has entered the business lexicon....,
“... what walks out of door at the end of the day. ".. knowledge that can
be converted to value", and finally "We believe that intellectual capital is
not a new category of business assets but rather a different way of classifying
business assets in order to focus on their management. Intellectual capital is
said to be a combination of human capital, intellectual assets, and intellectual
property”;; software life 10 to15 years and likely increasing.,
[SmithUA:88] Dudley B. Smith,
David S. Urey, and Cruzan Alexander ): The
Basics of Licensing, including International Negotiating Thesaurus;
Licensing Executives Society (LES), Norwalk CN, 1988.
[SmithV:97]
Smith New Court Ltd v Scrimgeour Vickers (Asset
Management) Ltd [1997] AC 254, Lord Steyn said East
‘shows that an award based on the hypothetical profitable business in which the
plaintiff would have engaged but for deceit is permissible: it is classic
consequential loss.’ Ref is Maurer fraudulently told East he would not run a
competing hair salon, so East bought the salon from Maurer. Maurer started run
a competing hair salon. East lost business. East then sued Maurer for deceit.
Court of Appeal Citations [1991] 1 WLR 461
[SofkaS:04] Wolfgang Sofka and Tobias Schmidt:: I Like the Way You Move: An Empirical Investigation into the Mechanisms Behind First Mover and Follower Strategies; ZEW - Centre for European Economic Research Discussion Paper No.04-087, 2004; SSRN library 167330. Recommended by Panagiotis G. Ipeirotis <panos@stern.nyu.edu>. , we find that firms that choose a first mover strategy operate in industries > with intensive knowledge exchange, additionally leveraging this advantage > through excellent absorptive capacities. [...] On the follower side we identify companies that operate in industries with a > lack of external knowledge spillovers to benefit from...they do not so much > rely on external information sources as on internal operational excellence > and efficiency. This allows them to compete on lower costs once an > adventurous first mover has sufficiently reduced uncertainty in the > industry.."
[SolomonS:09]
Charlene Solomon and Michael S. Schell:Managing Across Cultures: The
Seven Keys to Doing Business with a Global Mindset; McGrwa-Hill, 2009. Abstracted by Gary [Stern:10] . Focus on Culture. Much
on exopatriates.
[SolutionMatrix:07]
Ltd, Boston, MA 2007. <http://www.solutionmatrix.com. “Economic Life: The period of actual usefulness of an asset.
Economic life refers to the period beyond which it is cheaper to replace or
scrap an asset than to continue maintaining it. Not to be confused with depreciable life“;
[Corporations kept $222.7 billion in federal revenue from 2008 to 2010.
[Sougiannis:94] Theodore Sougiannis: “The Accounting Based Valuation
of Corporate R&D”; The Accounting
Review, Vol.69 No.1, Jan.1994, pp.44-68 at 65. File GbG/refs/Sougiannis.pdfl>. On
the average a $1 increase in R&D spending leads to a $2 increase in profit
over a seven year period and a $5 Market value increase. Some is due to shareholders
seeing and valuing IP R&E credits are considered.
Sowell:11] Thomas Sowell: Basic
Economics: A Common Sense Guide to the Economy, 4th Edition;
Basic Books, 2011
[SpitzerWW:06]
Cindy Spitzer, Bob Wiedemer, David Wiedemer: America's Bubble Economy, Profit when it Pops; Wiley, 2006. Buy Gold
<diatribe>
[Spolsky:02]†
Joel Spolsky: The Economics of Open Source; 12 June 2002, <http:www.joelonsoftware.com/articles/StrategyLetterV.html>, reprinted in [Spolsky:04]†
[Spolsky:04] Joel
Spolsky: Joel on Software; Apress,
2004.
[SpringerEa:11] Pamela Springer et al.: Manta, Where small business
grows; retrieved 2011. <http://www.manta.com/coms2/page_about_manta>. data site;
[Sproch:12]
Jim Sproch: Taxation of the High Tech Industry; class report, Stanford CS 207,
Dec.2012.
[SSA:11] SSA: Social Security History; <http://www.ssa.gov/history/briefhistory3.html>, and <http://www.ssa.gov/history/BudgetTreatment.html>, retrieved Oct 2011.
[SSN:11] Social Security Online: Wage Statistics for 2010; 30
Oct 2011, compensation intervals with
counts, <http://www.ssa.gov/cgi-bin/netcomp.cgi?year=2010.
[Stack:12] Kevin M.
Stack Interpreting
Regulations; Michigan Law Review, 2012, 111
Mich. L. Rev. 355.
[Staff:12] Staff at PanamaLow.org: Nevis LLC and Nevis Bank account; http://www.panamalaw.org/nevis_llc_and_nevis_bank_account.html, retrieved 30 April 2012
[Stahl:11] Leslie Stahl: A look at the world's new corporate tax
havens; CBS News, 60 minutes, 25 March 2011; http://www.youtube.com/watch?v=MxgezC4KhXQ "We can't write a law their lawyers can't get around.
That's the whole problem here”; [Congressman] Doggett explained. "You're
in Congress. Why did Congress write these laws that allowed this to
happen?" Stahl asked. "There's
been a lot of arm twisting, a lot of effective lobbying here, and some really
smart tax lawyers figuring out how to game the system with one shenanigan after
the other”; the congressman replied. "But are they shenanigans or is it
the law?" Stahl asked. "I think it was a shenanigan when some of
these companies felt so strongly about America that they renounced their
American citizenship and began saluting a foreign flag. They exploited a
provision in our tax laws and moved offshore”; Doggett said. Read more: <http://www.cbsnews.com/stories/2011/03/25/60minutes/main20046867.shtml>#ixzz1HumZMSG8>
Standard
& Poors:09] sources for corporate data: Standard & Poors and Moody's
databases to ascertain companies with same SIC code, see also SEC filings and
10-K exhibits for companies in same SIC code; retrieved 2009.
[Stapleton:12] Michael
Stapleton: Why Ireland? Investing and Setting up a Business in Ireland; IDA
Ireland, Sep.2012. Replaces [Infront:11]‡
<http://www.statistiques.public.lu/>
[Stein:74]
Herbert Stein, chairman of the Council of Economic Advisors, Nixon
administration] , 1974. quoted by Ben Wattenberg, House Ways&Means
committee, Social Security Hearings, 21 Sept 2000. << UIUC quote of the
day, 13 Oct 2004>> An unsustainable trend cannot be sustained. If
something is unsustainable, it tends to stop.
[Stein:12]
Jerome L. Stein: Stochastic Opmal Control
and the U.S. Financial Debt Crisis; Springer 2012.A contribution for the Financial Crisis
Inquiry Commission, applicable to fincial products with tranches of different
risks..The forst theory of Welfare Economics: Competetive Equilibrium is
[automatically] a Pareto Optimum.
[Stengel:72]†
Casey Stengel 1891-1972]†: "Never make predictions, especially about the future" Nothing is harder to predict than the
Future. Authorship not verified, also
attributed to Mark Twain, Yogi Berra (The future ain't what it used
to be. ),
[Stern:10]
Gary M. Stern: Taking The Bite Out Of Moving Overseas U.S. players span
culture gaps in foreign markets; Investor’s Business Daily, Jan.11, 2010.
[2]
Stern:11] Andy Stern: "China 's Superior Economic
Model"; Wall Street Journal, 1
Dec.2011. At
Columbia Un. Rickman center. Quoted Robert Engle"while China is making
5-year plans for the next generation, Americans are planning only for the next
election". Agricultural revolution took 3000 years, the industrial
revolution 300 years and this technology-led global revolution will only take
30-odd years. Cites .
[Stetar:03] Bill Stetar: Can We Really Measure
Training ROI?; slides, DoE training Symposium, Univ. of Tennessee. IP investment.
[Steuer:86] R.E. Steuer: Multiple Criteria
Optimization: Theory, Computattion, and Application; Wiley, 1986. Pareto Optimality.
[Stewart:98]
Thomas A. Stewart: Intellectual Capital: the Wealth of Organizations;
Currency, 1998.
[Stewart:11] David Stewart: “IRS to Take a ‘Fresh Look’ at Cost
Sharing Case Inventory, Transfer Pricing Director Says”; Tax Notes, 28 July 28, 2011. Notes from 27 June 2011 speech by Sam Marucca. CIP has
to be revisted because of Veritas case..
[Stewart:12] James
B. Stewart: “Tax me if you Can”;
New Yorker Magazine, 19 March 2012, pp.46-53. Residency and New York City tax.
[Stewart:12D]
David Stewart: Cost Sharing Regs Bar Retroactive Adjustments to RAB shares,
Officials Say; Tax Notes Today, 14 March 2010.
Joseph L. Tobin, senior counsel, branch 6, IRS Office of Associate Chief
Counsel (International), explained that the new language added to reg. section
482.7(e)(1) on RAB makes it clear that taxpayers may not use information
acquired later to make a retroactive change, but that the IRS may still make
retroactive adjustments.
[Stiglitz:06] Joseph
Stiglitz: Making Globalization Work;
Norton 2006. Ex World bank, Nobel laureate, now at Columbia Univ. No mention of
taxhavens in index. Have.
[Stiglitz:10]
Joseph Stiglitz: Freefall, paperback
edition; Norton 2010. 2007-2009
recession. have
[Stiglitz:12]
Joseph Stiglitz: The Price of Inequality:
how todays Divided Society Endangers Our Future; Norton 2012. Ex World bank,
Nobel laureate, now at Columbia Univ. elaboration of his 2011 Vanity Fair
article "Of the 1%, for the 1%, by the 1%." have
[Stobbs:00]† Gregory Stobbs: Software Patents, 2nd ed.; Aspen publishers,
2000.
[Stockman:13] David Stockman: The Great Deformation:
The Corruption of America; 2013. Diatribe.
[StolowyJ:01] Hervé Stolowy and Anne Jeny-Cazavan: “International
accounting disharmony: the case of intangibles”; Accounting, Auditing & Accountability Journal, MCB UP Ltd.,
2001, Vol.14 No.4, pp.477–497.
{Stone:11}
pre IPO
valuation by early shareholder sales. Replaced by [Protalinski:12]‡
[Stone:12] Chad Stone: Pols Be Warned: Closing
Loopholes Will Be Tough; Economic Intelligence, US News & world report; 18
Oct. 2012.
[Stossel:12] John Stossel: No,
They Can't, Why Government Fails-But Individuals Succeed; Threshold
Editions, Simon and Schuster Digital Sales Inc, 2012.
[Stout:12] Lynn A. Stout: The Shareholder Myth; Berret-Kohler, 2012. slim
and elegant polemic, explains the idea's two problems: It's worked out
horribly, and as a matter of law, it's not true.[Eisinger:12] . The biggest ill
has been to align top executives pay with performance, usually measured by the
stock price. This has proven to be "a disaster She advocates what
campaigners have called the "Robin Hood tax" — a transaction charge
on securities trades. A small tax would curtail zero-sum, socially useless
trading and might insulate corporations
[Studt:07] Tim
Studt: “R&D Outsourcing Becomes More Strategic”; R&D magazine, June 2007, pp.26-29; www.rdmag.com; guidance/references. Survey data on quantity, who, type, why
not (58.4% IP), why, where, motivation.
Globalization.
[Styron:07] W.
Joey Styron: “Transfer Pricing and Tax Planning”; CPA journal, Vol.77 no.11, 2007 pp.40-45. DISCs and FSCs, PAD, Domestic
Production Activities Deduction. Use of CFCs. Restates Regs., Coparabilty is
they key. “the taxpayer can effectively plan transfer prices to reduce taxes
for the dontrooled group as a whole”.
[Sullivan:04] Martin
A. Sullivan: “Data Show Dramatic Shift of Profits to Tax Havens”; Tax Analysts, 2004. Repatriation
questions. ..[ACM].
[Sullivan:05] Martin Sullivan: ;Tax Notes in 2005 mention 50B removed. 2004 repartition at 5.25%. Total
Corporate taxes 354Billion.
[Sullivan:06] Martin
A. Sullivan: “Drug Firms Move Profits to Save Billions”; Tax Notes, TaxAnalysts, 7 Aug.2006. Income Transfer offshore after Puerto
Rico phase-out. ..[ACM].
; From 1999 to 2007, U.S. multinationals eliminated 1 million jobs at home while adding 2.5 million jobs abroad. ..[ACM].
Martin A. Sullivan: “Pharmaceutical
Companies Keep Profits Abroad”; Tax Notes, Mar.2010. Quoted in Bloomberg Business Week, 29
December 2010. ..[ACM].
Martin A. Sullivan: “Repatriation Holiday Would Destroy
American Jobs”; Tax Notes,
15 Nov.2010.
..[ACM].
[Sullivan:11C]‡ Martin Sullivan: Testimony before the House Ways and Means
Committee; 20 Jan 2011. Data on effective taxrates of 14 companies, effect of
taxhavens. Job creation. Taxhaven profitability. Transfer pricing. Arms’s length flawed.. pharmaceutical.
Ignores finacial taxhaven transfers. ..[ACM].
[ACM].
..[ACM].
Thomas A. Zaccaro, and Adam D. Schneir: The SEC’s View of Auditor Independence;(Paul, Hastings, Janofsky, & Walker LLP).
[Sultanoğlu:98] Sencer Sultanoğlu and Ümit Karakaş: Cost Estimation Models. Hacettepe Üniversitesi, Oct.1998. <http://yunus.hacettepe.edu.tr/~sencer/cocomo.html>
NBER Book Series Tax Policy and
the Economy; NBER, Vols.1-24,
1987-1990.
[Summers:88]
Lawrence H. Summers, ed., Tax Policy and the Economy 2; MIT Press, 1988,
p.120. Contains
Roger H. Gordon and Joel Slemrod: “Do We Collect Any Revenue from Taxing
Capital Income?"
[Summers:13]
Nick Summers: “The Einhorn effect”: BBW, 25 Mar. 2013. Apply offshore holdings and a proposed
shareholder payout a scheme.
[SuringaM:01]
Dirk J.J. Suringa and Jeffrey Moeller: Foreign Personal Holding Companies; Tax
Management Inc., 2001.
Surowiecki:04] James Surowiecki: The Wisdom of Crowds; Doubleday, First Anchor Books, Random House, 2004.
[Surowiecki:09] James Surowiecki: The Debt Economy; The New Yorker, Nov.23, 2009. How the tax code
encourages Debt.
[Surowiecki:11] James Surowiecki: Innovative Consumption; New
Yorker Magazne, 16 may 2011, p,42. Cropbox, PC, Consumer willingness to take risk. [Box]
[SurreyM:74 ] Stanley S. Surrey and
Paul R. McDaniel: Pathways to Tax Reform: The Concept of Tax Expenditures; Harvard University Press, 1974
Paul R. McDaniel: Tax Expenditures; Harvard University Press, 1985.
Sveiby:97] Karl-Erik
Sveiby: The New Organizational Wealth;
Berrett-Koehler publishers, San Francisco, 1997. IP assets score sheet, including worksheet, Used by
Infosys. Focus on publishing segment.
Intellectual capital should be on the books.
[Swenson:01] Deborah
L. Swenson: “Tax reforms and Evidence of Transfer Pricing”; National Tax Journal, Vol.54 no.1, March
2001, pp.7-25. Also UC Davis and NBER, 2000. <http://www.econ.ucdavis.edu/faculty/dswenson/Research/TPRICING.Sept00.pdfl>. Problems with intangibles are worse.
Tangibles: … reported prices rise when
the combined effect of taxes and tariffs provides an incentive for firms to overstate
their prices. While the results are statistically significant, they are
economically small, implying that a 5%decline in foreign tax rates causes the
reported price of affiliated firm imports to rise by 0.024%. Because transfer
price manipulation is predicated on the actual flows of goods among countries,
this method of moving income may be more costly than other methods of income
shifting. While the manipulation of intra-firm trade transfer prices represents
one potential avenue for income shifting, my evidence from trade transaction
prices suggests that the manipulation of product transfer prices is not
generally responsible for large movements in reported income.
[SwensonS:11] C. David Swenson and Gary B. Stone: Transfer
Pricing Perspectives ; Thought Leadership Journal, Price Waterhouse Coopers,
PWC, 2011. Disputes
increasing in MNC’s 2005=2007, more
transparency, more audit requests, Disturbing trend for MNC’s. Defiuning
jurisdiction for Permannt Establishment (PE).
Frmulary allocation, risk assumption. . Conflict between taxpayes and
IRS in cost-sharing philosophical difference.
Binary `baseball arbitration’ chills (Apple/IRS 1993). Also on court
cases. No solution found to double taxation in complex cases. Triangular cases
(dutch sandwich) examples. APAs. Canad CRA, jaoan NTA MAP – Mutual agreement procedures among
countries.
[Taleb:07] Nassim Nicholas Taleb: The Black Swan: The Impact of the Highly Improbable; Encounter
Books, Random House, 2007. On the very small and impossible to predict chance of an
event with a very large impact.
[TamaiT:92]†
Tetsuo Tamai and Yohsuke Torimitsu: "Software Lifetime and its Evolution
Process over Generations"; Proc.
Conf. on Software Maintenance, ICSM,
Nov.1992, pp.33-37.
[Tamai:02]†
Tetsuo Tamai: "Process of Software Evolution"; First International Symposium on Cyberworlds, Tokyo, Nov.2002,
p.8-15.
[
[Tang:93] Roger
Tang: Transfer Pricing in the 1990’s: Tax
and Management Perspectives”; Quorum, 1993. A GAO survey of 519 multinationals in 1980/1981
revealed that 60.1% of IRS adjustments (as measured as a percent of total
dollar adjustments), represented pricing adjustments. In terms of dollar
volumes, pricing adjustments were followed by adjustments to income allocation,
expense allocation, intangibles, services, interest, rentals, and gain
allocation.
[TanPH:08]
Hong Pew Tan, David Plowman, and Phil Hancock: "The Evolving Research on
Intellectual Capital; Journal of
Intellectual Capital, Vol.9 No.4, Emerald publications, 1469-1930, 2009, pp.585-608.
[Tanzi:00]‡ Vito Tanzi: Globalization, Technological Developments,
and the Work of Fiscal Termites; IMF Working Paper number 00/181, Nov.2000. Termites are 1.
Electronic commerce &sale of digital goods from tax havens. 2. Electronic
money 3. Inracompany trade 4 offshore finacial centes, Derivatives and hedge
funds 6. Inability to tax capital. & forieign activities and ssavings, 8
foreign shopping.
[Tanzi:11] Vito Tanzi: Government versus Markets: the Changing
Economic Role of the State; Cambridge University Press, May 2011. The author is a skeptic of a large paternalistic state
and believes that the governments roles are to regulate markets and let private
competition be the source of growth rather than governments fill the role of
markets with failures. Given the externalities of many markets the author does
not believe prices act as signals in many modern day industries and information
asymmetries need to be fixed by the state. Government versus Markets is a good
overview of a subject which will no doubt be a major topic of discussion in the
coming decades. On the one hand, the welfare state seems to have become
unsustainable and requires deep structural change to provide the populations
that reside within them the opportunities that they deserve but at the same
time small government reduces the voice of the community in an increasingly globalized
world [Amazon reviews] .
[TanziS:00] Vito Tanzi and Ludger Schuknecht: Public Spending in the 20th
Century: A global Perspective; Cambridge Univ. Press, 2000. Have. Much social
redistributive spending is just churning. Transparency of subsidies is need for trust. Favors privatization to
reduce governments share of GDPs
[TaxF:11]
Tax Foundation: National Corporate Tax Rates;
<worldwide-tax.com>. United States -
47% (Federal 35% + State maximum 12%) Canada - 36.1% Mexico - 29.0% China -
25.0%
[Taxhelp:03]
The professional edge, Taxhelp@tax-help.com, Vol III no.1, 2003.
[Taylor:08]
John B. Taylor: Global Financial Warriors; W.W. Norton, 2008. Taylor rule for Fed.Reserve interst rate and
unemployment ?
[TaylorFC:06] Paul, , Cary Funk, and Peyton Craighill: A Barometer
of Modern Morals; Pew Research Center.
Washington DC, 28 Mar.2006. Washington DC
Princeton Survey approved tax evasion (79%) follows cheating on ones’ spouse
(88%).
[TempleWest:12] Patrick Temple-West: IRS forms `Swat Team’ for Tax
Dodge Crackdown’; Accounting Today,
20 Mar.2012. Report on Maruca appointment by Dolan, KPMG, ex IRS . More hiring in the
face of budget cuts . Hiring econmists from accounting firms for transfer
procibnnfg, 40 on-board, 60 to come. Budget cut 2.5% Underpaid and Outgunned ,
Skepticism about Maruaca’s chances. Dolan questions if resources are
sufficient. Problem with intangibles.. Court decisions lost. Also in Huffington Post / Reuters, 20 March 2012.
[TempleWest:12C]
Patrick Temple-West: IRS Chief: Congress Not Acting `Real Disaster’; Huffington
Post 5 Apr.2012. Shulman –
tax delays, Exempting provions
[Teplykh:13] Grigorii Teplykh: Specificity of
Corporate Value Creation in Different Types
of Companies; National Research University Higher School of Economics, Perm, Russia, 5th European Conference on Intelectual
Capital, Bilbao, Spain. April 2013.
[TerrP:77]
Leonard Brian Terr and Gordon O. Pehrson, Jr.: Foreign Corporations:
Reorganizations, Liquidations, and Similar Transactions; Bureau of National
Affairs, 1977. Bio on Amazon
[Terr:10] Leonard
B. Terr (chair): Handling Federal Tax Controversies in the United States; North
American Tax Practice Group, Baker & McKenzie, 2010. Chair 2011 is Leonard B. Terr. (Terr's
master's thesis was on "Shaftesbury and the Augustan Compromise”; A.M.
thesis, Brown University, 1968 (focusing on 18th century English literature and
the Earl of Shaftesbury, Anthony Ashley Cooper (1671-1713)).
[TewaryEa:12] Akshat
Tewary, Alexis Goldstein, Corley Miller, George Bailey, Caitlin Kline,
Elizabeth K. Friedrich, Eric Taylor, et al.: Re: Prohibitions and Restrictions
on Proprietary Trading and Certain Interests in and Relationships With, Hedge
Funds and Private Equity Funds; Occupythesec.org, 2011, RIN 1557-AD44; RIN 7100
AD 82; RIN 3064-AD85; RIN 3235-AL07; <http://www.occupythesec.org/letter/OSEC%20-%20OCC-2011-14
- Comment Letter.pdfl>.
[ThalerS:08] Richard H. Thaler & Cass R. Sunstein,
Nudge: Improving Decisions About Health, Wealth, and Happiness; Yale Univ.
Press, 2008
[Thiess:11R] Rebecca Thiess: Republican Proposal to
`right our fiscal ship’ throws more workers overboard; Economic Policy
Institute, 9 Feb 2011.
[Thiess:11D] Rebecca Thiess: Discretionary Spending
Cuts Would Reduce Jobs. Hurt Social programs,; Economic Policy Institute, 25
Jan.2011.
[Thiess:12]‡ Rebecca Thiess: `Small Business’ and Top
Marginal Rates. Tax filers affected by proposed rate increases are not
necessarily small, or businesses, or job creators; Economic Policy Institute,
Issue Brief no.349, 13 Dec.2012. Thorough comparison of the variety of metrics
[Thomas:11] Library
of Congress: THOMAS; The official source for legislative information; <http://thomas.loc.gov/home/thomas.php>, accessed 2011.
[Thomas:05] Chantal Thomas: “Trade-Related Labor and
Environment Rights Aggreements”; in [ChoiH:05] , p.108-133. WTO and IP rights trade under TRIPS.
[Thomas:08]
Jerry W. Thomas: Advertising effectiveness; Decision Analyst, 2008. Focus on quality
[Thomas:12] Ken
Thomas: “Who’s the Rich Guy?”; Associated Press, Miami Herald, 10 April 2012.
[Thomas:12O] Landon Thomas jr.: Offshore Haven
Considers a Heresy: Taxation; The New York Times, 3 Oct 2009. Budget problems in Cayman Islands.
[Thompson:12]
Derek Thompson: How We Pay Taxes: 11
Charts; The Atlantic, 16 April 2012
[ThompsonZ:11] Mark Thompson and Terri LaRae
Zuraff: Export Tax Incentives (Portfolio
934); BNA Tax & Accounting, Product Code: TPOR43 Edition Code: TMF934
$400.00
[Thornton:02]
E.A. Thornton: “Valuation of Software Intangible Assets”; ASA International Conference. San Diego, CA. Aug.2002.
[Thornton:04] Mark Thornton: How Outsourcing Creates
JOBS; 11 April 2004, lew Rockwell.com..
[Thorpe:10] Simon Thorpe: A flat rate Financial
Transaction Tax to replace all taxes; CNRS, Toulouse, France, 29 Oct 2010. simon.thorpe@cerco.ups--‐tlse.fr.. has some numbers. post at http://simonthorpesideas.blogspot.com/ Zero rate for
repatriation.
[Thomson:12]
Ainsly Thomson: “U.S. Firms Face
British Grilling on Tax Practoces”; The
Wall Street Journal, 12 Nov. 2012. Google, Amazon, and Starbucks were accused of being
immoral.[ACM].
[Tichon:09] Nicole Tichon: "Tax Shell Game: The Taxpayer Cost
of Offshore Corporate Havens"; U.S.
Public Research Interest Group, April 2009. <http://www.uspirg.org/news-releases/tax-and-budget/tax-and-budget-news/washington-d.c.-taxpayers-footing-a-100-billion-bill-for-tax-dodgers>. Annual loss is $100B.
[ACM]
[Tichon:12]
Nicole Tichon: "The Ex-Patriopt Game of Hide and Seek; Huffington Post, 19
Jul.2012. Romney
et al. contributiong to a $100 billion US treasury revenue shortfall. Busienss
tax rates are 12% average [ACM, http://www.huffingtonpost.com/nicole-tichon/expatriot-games-more-than_b_1680250.html]
[TillquistR:05]†
John Tillquist and Waymond Rodgers: "Using Asset Specificity and Asset
Scope to Measure the Value of IT"; Comm.
ACM, Vol.48 No.1, Jan.2005, pp.75:80.
[Timiraos:07] Nick Timiraos:
Businesses Battle Over Patent Law; Wall
Street Journal, 9 June,
2007; Page A7.,
[<http://online.WSJ.com/article/SB118134901470729714.html>?mod=Review-Outlook-US]
Cites
Blackberry, research in Motion patent, settled for $162M. Sevearl patent facts. U.S. businesses today
invest as much in intellectual property and other intangible assets, about $1
trillion, as they do in equipment, factories and other physical investments,
according to a Federal Reserve Board study.
Intangible assets, including intellectual property, account for nearly
one-third of the value of all U.S. stocks, about $5 trillion to $5.5 trillion,
or 45% of U.S. GDP. Innovation fueled about four-fifths of the productivity
gains during the economic boom of the late 1990s. [ACM]
<http://www.taxjustice.net/cms/upload/pdfl>/tuiyc_-_eng_-_web_file.pdfl>
[TJN:06] A Tax Justice Glossary;
Tax Justice Network,
Sep.2006. Superseded
by [MurphyEa:09] .
[TJN:07]
Tax Justice Network: Identifying Tax Havens and OFCs, Tax Justice Network, 2007. From
Vaibhav CS207.
[TJN:12]
Tax Justice Network: Time To Tackle Tax Havens; The Tax Justice Network
International Secretariat Limited, 38 Stanley Avenue, Chesham
Buckinghamshire, United Kingdom, HP5 2JG, < http://www.tackletaxhavens.com/>
[Tobin:69] James Tobin: "A general equilibrium approach to
monetary theory"; Journal of Money Credit and Banking, Vol.1 no.1, 1969, pp.15–29.
[TobinB:77]‡ James Tobin and William Brainard: "Asset Markets and
the Cost of Capital"; Chapter 11 in
William Fellner, Béla A, Belassa and Richard Nelson : Private Values and Public
Policy, North-Holland 1977. Replacement cost of
tangible assets, and value lag. 15years? .
[Toder:00] Eric J. Toder: “Tax Cuts or Spending—Does it Make a Difference?”; National Tax Journal, Vol.53 no.3, part
1, Sep.2000, pp.361-372.
[Toder:11] Eric
Toder: Closing Loopholes Won’t be Simple; The
New York Times, 2 Feb.2011.
[ToderB:07] Eric J. Toder and Lily
Batchelder: “Business Taxation”; Chapter II-12, The Tax Policy Briefing Book, Urban-Brookings Tax Policy Center, Dec.2004.
[Toombs:13] Zach Toombs: “Passage of tax deal hangs in the Balance”;
New York Times, 2 Jan.2013. Puerto Rican rum tax relief and NASCAR ,
atc., added to Sandy relief bill.
[TorvaldsD:01]
Linus Torvalds and David Diamond: Just for Fun: The Story of an Accidental
RevolutionaryHraber Business Reprint, 2002
Includes observation on IP. [ACM].
[TownsendJ:99] John A. Townsend and Lawrence R. Jones, jr.: DHL - A Strategy Lesson in Transfer Pricing Controversy; Townsend
& Jones Newsletter, January 1999. arbitrary,
capricious, or unreasonable
[Townsend:09]‡
John Townsend: “Tax Ostruction Crimes: Is Making the IRS’s Job Harder Enough?”;
Houston Business and Tax Journal,
Vol.9, 2009. A list of 27 legal - even morally neutral objective –means to
exploit IRS inefficiency, even increasing increasing tax payments to avoid
audits.
[Townsend:11]
John A. Townsend, Larry Campagna, Steve Johnson, and Scott Schumacher: Tax
Crimes 2008; <http://www.tjtaxlaw.com/, 2011.
[TownsendCJS:08]
John Townsend, Larry Campagna, , Steve Johnson, and Scott Schumacher: Tax
Crimes 2008; LexisNexis, 2008.
[Tozzi:12]‡
John Tozzi: A Shrinking Contribution ; Bloomberg Businessweek, 20 Feb.2012,
p.56. Small
business smaller fraction of GDP.
[TPC:11G]
The Gingrich Plan; 12 Dec.2011, http://www.taxpolicycenter.org/taxtopics/Gingrich-plan.cfm
[TPC:11P]
Governor Rick Perry’s Tax Reform Plan; 22 Nov.2011, http://taxpolicycenter.org/taxtopics/upload/Perry-Plan-description-TPC-11-2-11-2.pdf.
[TRA:76] TRA 76 Privacy law first 1976, after Watergate
Pub. L. no.94-455; JCT, Study of
Present-Law Taxpayer Confidentiality and Disclosure Provisions, Vol.1 at 255,
[TRA:96]‡
US Congress: The Tax Reform Act of 1996; section 8670;
[TRAC:08]‡ TRAC IRS:
Audits of Largest Corporations Slide to All Time Low; Transactional Records
Access Clearinghouse, Syrcuse University, 14 April 2008. co-director Susan
Long. audits of corporations reduced by 20% between 2002 and 2007. Corporation with assets of less than 50M
increase by about 30%, of less than 250M decrease by about 30%,,greater
decrease by nearly 40%. more audits of passthroughs 239 -> 316 staff hours versus corporations
2.763 - @.153 , (in which large corps 2.284-1,610. Based on Rosotti sept 2002,
IRS data books, 2001-2007.
[Tracy:93]
John A. Tracy: How to Read a Finacial Report, 4th Edition; Wiley,
1993. Nice
introduction. but ignores people, R&D, and IP.
[Trivedi:12D]
Shamik
Trivedi: “Danilack sees more exam efficiency
with transfer pricing organizational changes”; Tax Notes Today, June 8, 2012
[Trivedi:12] Shamik
Trivedi: “DeNard Describes Impending
LB&I Domestic Realignment”; Tax Notes
Today, 4 Oct.2012. L&BI realignment
11] TTB: About TTB; The Alcohol and Tobacco Tax and Trade
Bureau of the U.S. Treasury, www.tbd.gov/about, 2011.
[TuerffEa:08] T. Timothy Tuerff (Deloitte), Daniel Shaviro (NYU),
Douglas A. Shackelford (UNC), Timothy M. McDonald (Procter&Gamble), and
Michael Mundaca (Treasury): “Panel Session 4: Alternatives for Taxation of
Foreign Source Income”; Taxes—The Tax Magazine, CCH publishers, June
2008, pp.71-86. Subpart F. Territorial vs World wide. Reforming Deferral Rules. Consumption
tax. Non-corporate business paid 51.5% of business taxes in 2004. MacDonald: I believe that incremental change, although politically the easy thing to
do, is probably the worst thing we can do for the economy and for our long term
standard of living, which I think was the point made from some of the other
panels. So it is time to buckle down and get this debate outside of the tax
community and developed in such a way so that regular citizens, i.e., voters
get all the facts and the likely real consequences of the difficult choices
that will need to be made. I think this is tough enough for the tax people, but
people that do not have the business background, let alone a tax background,
need to understand what this issue is about and the economic consequences of
these tough policy choices. I think there needs to be a lot more discussion,
articles, and a robust agreement as to how do we raise the standard of living.
[Tyson:11] Laura d'Andrea Tyson: The Logic of Cutting Corporate Taxes; The New York
Times April 8, 2011. Mentions
S-corporations.
[Tyson:13]
Laura d'Andrea Tyson: “Modermizing Corporate Taxation”; Het Financieele Dagblad & Reuters,
28 Jul.2013. Will be a key agenda point at the upcoming G-20 summit in Russia. Favoers
lower rates and territorial taxation, ignoring IP and taxhavens.
[Tzu:340BCE] Sun Tzu: The Art
of War, translated by Samuel B. Griffith; Oxford University Press, 1983.
Consider five factors: `moral standing, the climate, the terrain, command
capability, and doctrine’
[UN:05] United Nations, Economic and Social Council Committee of
Experts onInternational Cooperation in Tax Matters, Nov.2005, Abuse of tax
treaties and treaty shopping.
[UN:06] United Nations,
Economic and Social Council Committee of Experts on International Cooperation
in Tax Matters, Oct.2006, Treaty abuse and treaty shopping
[UN:07] United Nations,
Economic and Social Council Committee of Experts on International Cooperation
in Tax Matters, Nov.2007, Improper use of treaties
[Urdank:11]
Albion Urdank: Can Britain really Proper ‘Unfettered by the EU?; WSJ, 31 Dec
2011. Cameron acts as a representative of the City of London.
[US:06] United States
Model Income Tax Convention of Nov.15, 2006, United States Model Technical
Explanation Accompanying The United States Model Income Tax Convention of
Nov.15, 2006
[UScensus:08]
U.S. Census Bureau: Statistics about
Business Size (including Small Business);
US Department of Commerce, 2010, http://www.census.gov/econ/smallbus.html.
[UScensus:10] U.S. Census Bureau: Facts about the Census 2010
Residence rule; US Department of Commerce, 2010.
[USCoC:11] U.S. Chamber of Commerce: Jobs Agenda, Intellectual
Property; <http://www.uschamber.com/ip, 2011. IP-intensive
industries employ 19M workers; they average a 60% greater salary than similar
workers in non-IP intensive industries, IP-intensive industries generated
$7,700B in gross output, over 33.1% of U.S. GDP, and account for about 60% of
US exports, $910B in 2007.
[USCongress:96]
National Securities Markets Improvement Act of 1996; Public Law 104–290—Oct.
11, 1996, 15 USC 78a. Requires consideration of economic consequences of regs. See
BW 30 Jan 2012.
[USCongress:12]
The family and business tax certainty act ...july 2012.
[USConst:1787]
Constitution of the United States; 1787. Article 1, section 8: The power of Congress. 17
Sep.1787, ratified 21 June 1788.
[USHTS:10]
Harmonized Tariff Schedule; U.S. Customs Service, ... , 2000 pp.Enabled as
Chapter 4—Tariff Act of 1930, Subtitle I—Harmonized
Tariff Schedule of the United States (§ 1202)
[USPAP:04]
The Appraisal Foundation: 2004 Edition of the Uniform Standards of Professional
Appraisal Practice , Standards 9 & 10: Business Appraisal, https://www.appraisalfoundation.org/html>/standards.asp?FileName=current_uspap, Jan 2005. For intangibles
cost is not cited as a method.
[USPAP9:04]
The Appraisal Foundation: 2004 Edition of the Uniform Standards of Professional
Appraisal Practice , Standard 9: Business Appraisal, Development, Jan.2005,
<https://www.appraisalfoundation.org/html>/standards.asp?FileName=current_uspap>. Binding rule 9.2
(g) :"
Rule 9.2 binding requirements from which departure is
not permitted
(g) any
hypothetical conditions necessary in the assignment.
Comment: A hypothetical
condition may be used in an appraisal only if:
use of the hypothetical condition is
clearly required for legal purposes, for purposes of reasonable analysis, or for purposes of comparison;
use of the hypothetical
condition results in a credible analysis; and
the appraiser complies with the disclosure
requirements set forth in USPAP for hypothetical conditions. “
<http://www.appraisalfoundation.org/html>/USPAP2004/standard9.htm>
[USPAP10:04] The Appraisal Foundation: 2004 Edition of
the Uniform Standards of Professional Appraisal Practice , Standard 10:
Business Appraisal, Reporting, Feb.2005.
If a Hypothetical condition or scenario is used, that should be clearly
stated in the appraisal document. Rule 10.1(c) <http://209.213.217.34/html>/USPAP2005/std10.htm>. "clearly and
accurately disclose all assumptions, extraordinary assumptions, hypothetical
conditions, and limiting conditions used in the assignment”;
[UStreasury:95]
An Analysis of the New Armey-Shelby
Flat Tax Proposal; U.S. Treasury Department, Office of Tax
Analysis, 1995; Tax Notes, Vol.70 no.4, 22
Jan. 1996, pp.451-461. Flat tax is like VAT, but also taxes individuals, but
businesses can deduct labor costs. In this revenue and distributional analysis
of one flat tax proposal it is concluded that it would be revenue-neutral at a
20.8%. Existing proposals would,
however, tend to increase the relative tax burden on the middle class.
[USTreasury:99] The Problem of Corporate Tax
Shelters, Discussion, Analysis and Legislative Proposals; U.S. Treasury Department, Office of Tax Analysis, white paper, July
1999.
[UStreasury:07] U.S.
Treasury: Report to Congress on Earnings Stripping,
Transfer Pricing and U.S. Income Tax Treaties; Treasury Department, Office of Tax Analysis, Nov.2007. U.S. multinationals
continue to shift income to low-tax jurisdictions.
[UStreasury:11] U.S.
Treasury Department: Investing in U.S.Competetiveness: The Benefits of
Enhancing the Research and Experimentation Tax Credit; Treasury Department, Office of Tax Policy, 25 March 2011. Supports Obama
2012 budget request.
[vanDijkWM:06]
Michiel van Dijk, Francis
Weyzig, and Richard Murphy: The
Netherlands: a tax haven?; Stichting Onderzoek Multinationale Ondernemingen,
Amsterdam, Nov.2006, at http://bit.ly/aC2zuB
(SOMO) also Francis
Weyzig, Michiel van Dijk, and
Richard Murphy in SSRN. SGI=BFI, IKEA. Assets held in SFI’s, about
20,000 80% no employees, about 100-125 really big. license payments examples. =
Duitch sdandwich. [xls/taxhavens]
[Valenduc
BS:03] Christian M.A. Valenduc, Hana Polackova Brixi, Zhicheng Li Swift: Tax
Expenditures - Shedding Light on Government Spending Through the Tax System:
Lessons from Developed and Transition Economies; World Bank
Publications, 31 Jan 2003.
[vanHiltenEa:10] Dirk van Hilten,
Richard Fletcher, Antonio Russo, Clive Jia-A-Joen, Margreet G. Nijhof, Pawel
Wrblewki: Maximizing Tax benefits from Intangible Property Develop-ment and
Ownership; Presentation slides, Baker McKenzie, Amsterdam, 10 March 2010, <http://www.bakermckenzie.com/files/Uploads/Documents/Amterdam/Ahead
of Tax/pn_amsterdam_aheadoftax_maximizingtaxbenefits_russovarious_mar10.pdfl>. The
authors are with James Hardie Industries (DvH), and (Baker & McKenzie
London (AR) and Amsterdam):
[VankeEa:12]
Jeffrey Vanke et al.: Primary Numbers:
The GOP candidates and the National Debt;
US Budget Watch, a Committee for a Responsible Federal Budget, 23
Feb.2012, <http://www.USBudgetWatch.org>.
[VatterW:96] Harold
G. Vatter and John F. Walker (eds.): History
of the U.S. Economy since World War II;
Sharpe, 1996. As of Dec.1985 Morgan
Guarantee estimated the net size of the Eurocurrency market at 1,668B, of which
1,251 would be Eurodollars.
[Vaud:09] Canton de Vaud: Economic Promotion; Office
for Economic Affairs, retrieved 2009, http://www.dev.ch/
[Vause:09] Bob
Vause: Guide to Analysing Companies, Fifth Edition; Bloomberg Press, 2009.
[VBM:04] Value
Based Management.net: The Value of Intellectual Capital, do intangible assets yield a return ... ?;
<www.valuebasedmanagement.net/faq_do_intangible_assets_create_value.html>,
2004. . For Research &
Development (R&D) (the only intangible asset reported separately in corporate
financial statements) there has been substantial research, showing that
estimated rates of returns are in between 20-35 percent annually.- The
contribution of basic research often turns out to be much bigger than the
contribution of product development or of process R&D (although riskier as
well). Refers to IBM:11
[Veon:03] Joan
Veon: Global Taxation And Tax Harmonization ; Aug.20, 2003
NewsWithViews.com. UN view.
[Veritas:09] US Tax Court; Veritas Software and Subsidiaries v. Commissioner of Internal Revenue; 133 T.C. no.14, Docket No.12075-06, filed 10 Dec.2009Tax Management Transfer Pricing Report,
VidanoT:07] Thomas A. Vidano
and Carol B. Tan: Request for comments on Temp. Treas. Reg. § 1.482-9T(b)(4)(i) Support services
among taxpayers in a variety of industry Sectors); IRS, Office of Associate Chief
Counsel (International), 2007. Markup 7%.
[Vogel:97] Klaus Vogel: On Double Taxation Conventions, A
Commentary to the OECD, UN and US model Conventions for the Avoidance of Double
Taxation of Income and Capital, With Particular Reference to German Treaty
Practice, London: Kluwer, 3rd ed, 1997.
[VolckerEa:10] Paul
A. Volcker (chair), Austan Goolsbee, et al.:
The report on Tax Reform Options, simplification, compliance, and
corporate taxation; The president’s economic recovery advisory board (PERAB), August 2010.
Deduction
of $500,000 for residence capital gains not relavnt if inflation indexed. Debt versus equity financing.
[
[W:92]†
Gio Wiederhold: "Mediators in the Architecture of Future Information
Systems"; IEEE Computer, Vol.25 No.3, March 1992, pages 38-49;
[W:95]† Gio Wiederhold: ``Modeling and Software
Maintenance"; in Michael P. Papazoglou (ed.): OOER'95: Object-Oriented
and Entity-Relationship Modelling; LNCS 1021, Springer Verlag, pp.1-20,
Dec.1995.
[W:98C]† Gio Wiederhold and CS99I class: Web growth (updated); 1998/2000, <http://www-db.stanford.edu/pub/gio/CS99I/2000/webgrowthslide.ppt>.
[W:03]‡† Gio Wiederhold: "The Product
Flow Model"; Proc. 15th Conf. on
Software Engineering and Knowledge Engineering (SEKE), Keynote 2, July
2003, Knowledge Systems Institute, Skokie, IL., pp.183-186.
<http://infolab.stanford.edu/pub/gio/inprogress.html#worth>
[WainerAS:13] David Wainer,
Gwen Ackermann, and Shoshanna Solomon: An Israeli Power Broker With an Empire
at Risk; BBW, 7 Jan 2013. Indirect
reference to recent Israeli regulations, promoted by Netanyahu, limiting new
holding companies to two levels of subsidiaries, and restricting existing ones
to three levels.
[Wald:98] Matthew
L. Wald: “F.A.A. Inspectors Are Divided Over Safety Violations by ValuJet”; The New York Times , 1 March 1998.
[Walden:05] Eric A.
Walden: Intellectual Property Rights and Cannibalization in Information
Technology Outsourcing Contracts; MIS Quarterly, Vol.29 No.4 - Dec.2005,
699-720. Importance of SW. SW as an outcome to be
allocated (not divided as in first par.) (but it is also an input!). Lengthy
intro with too many examples of tangibles. The last sentences p.702, col.2, par
1. are dumb, because they suppose that
investment is more than the value garnered, The reasoning does not apply at all
to cost-shared SW development. Since we base value on income, value is
verifiable (p.705, col.2 last par). Excludability implies risks in offshoring
(p.706, col,1. Last par.), including cannibalization (p.711, col.1). The payoff
alternatives could be interesting in comparing technical R&D investments
and marketing investments. But the model assumption is throughout that all
parties share the market, but in CFC contracts the markets are always
contractually disjoint, say North-America versus the rest of the world. This
choice is not listed as an alternative in Table 3. Globalization.
[Walker:06] David
M. Walker: Tax Compliance, Challenges to Corporate Tax Enforement; US 26pp.
[Walsh:01] Keith Walsh: The Economic and Fiscal
Contribution of US investment in Ireland; Journal of the Satistical and Social
Onquiry Society of Ireland; Vol.XL, no, 164, 1 dec.2010, pp.33-59. <http://www.ssisi.ie/jssisi_2010-11_full_volume.pdf>
Revenuue Commissioner,
IIIIS. US multinationasl contribute 1/3 of Irish Corporate tax revenues, 43% in
2009. Based on 84 US of the 250 largest irish compamies,
[xls/forest]
[Wamoff:12] Steve Wamoff: Policy Options to Raise Revenue;
Citizens for Tax Justice, 8 March 2012. Berhaviorl response to raising capital gain. $533/10 years. saved. S-corpotaions don’t pay medicare.
[Wanetick:09] David Wanetick: Strategic Implications of Trade Secrets; IP Frontline. Oct 19, 2009. <http://www.ipfrontline.com/depts/article.aspx?id=23656&deptid=2#
[Warwick:07]
Nelson Warwick: Fair Tax: A Wolf in
Sheep’s Clothing; Authorhouse, 2007. Diatribe
[Warstories:03]†
Histories of Electronics Companies, at
[http://www.warstories.cc/person/?personId=7], obtained 2003.
[Waters:12]
Richard Waters: Orcale faces Billion dollar bill from HP; FT, 1 Aug.2012. Example of
importance of continuity.
[Wayne:12] Leslie Wayne: How Delaware Thrives as a Corporate Tax Haven;The New York Times, 30 Jun.2012. 1209 North Orange
Streety: American
Airlines, Apple, Bank of America, Berkshire Hathaway, Cargill, Coca-Cola, Ford,
General Electric, Google, JPMorgan Chase, and Wal-Mart. Plus laundering illicit
money and criminal proceeds, Officials in the Cayman Islands, a favorite
Caribbean haunt of secretive hedge funds, say Delaware is today playing faster
and looser than the offshore jurisdictions that raise hackles in Washington.
Anthony B. Travers, chairman of the Cayman Islands Stock Exchange and former
chairman of that country’s Financial Services Association. “There should be a
level playing field and Delaware should have to comply with the same standards
as the Caymans.”. Last year, 133,297 businesses set up here. And, at last
count, Delaware had more corporate entities, public and private, than people —
945,326 to 897,934. Over the last
decade, the Delaware loophole has enabled corporations to reduce the taxes paid
to other states by an estimated $9.5 billion. Laszlo Kiss, an Romanian
accountant and author of “United States, Tax Heaven — Uncle Sam Will Fight Your
Taxes!” that praised the state’s lax rules. He is now awaiting trial in
Bucharest on charges of helping embezzle and launder $10 million through
Delaware shells. The New York Times Company has seven corporate subsidiaries
registered at 2711 Centerville Road in Wilmington. The registered agent for
that address is the Corporation
Service Company, which is the second-largest agent in
the state. Bradley P. Lindsey, an accounting professor at North Carolina State
University and one of three authors of a 2011 study titled “Exploring the Role Delaware Plays as a
Domestic Tax Haven.” Delaware does not tax certain
profit-making intangible items — like trademarks, royalties, leases and
copyrights. Yet those same intangibles can be part of a tax strategy that
allows them to be classified as deductions in other states, reducing a
company’s tax bill there. [ACM]
[WC:98] Gio Wiederhold and CS99I class: Web growth (updated); 1998/2000, <<http://infolab.stanford.edu/pub/gio/CS99I/2000/webgrowthslide.ppt>.
[Weber:68] Max Weber:
Economy and Society; Bedminster Press, 1968.
[Weiler:95] Dave G. Weiler: More
on Trademark Royalties; AUS, Mt.Laurel, NJ, 1995. Author is with AUS Consultants.
Analysis of DHL case. Chap.3, App.D.
[Weiner:09]
cited by MarkleS09. Elimination of deferral
[Weissler:01]‡
Robert Weissler: APA Study Guide; ; www.irs.gov/pub/irs-apa/apa_study_guide_.pdfl>, in 11
Transfer Pricing Report 533, 10/2/02 (filed in
guidance/references/Weissler, also CSA slides).
[
[WeisslerEa:02]‡
Robert Weissler et al.: CostSharing Workshop: Buy-in Payments; www.irs.gov/pub/irs-apa/study_guide_exhibit_e.pdfl>, Aug.2002. Six
valuation methods explained. Deals with small sales & royalties/(in
guidance/references/Weissler, also CSA slides, also in WT MA-695.) Refers to
[Morgan:99]‡
[Wessel:11] David Wessel: U.S. Firms Shift Hiring Abroad; Wall Street Journal, 19 April, 2011.
[Wessner:08] Charles W. Wessner (ed.): An Assessment of the Small
Business Innovation Research (SBIR)
Program; NRC, NAS, 2008.
Darrell
M. West, Technology and the
Innovation Economy; Governance Studies. The
Brookings Institution , 24Oct.2011. The United States spends only 2.8 percent of its
federal budget on national research and development as a percentage of GDP.
This is less than the 4.3 percent spent by the government in Sweden, 3.1
percent by Japan, and 3.0 percent by South Korea, but higher than that of
Germany (2.5 percent), <plus Fraunhofer> France (2.2 percent), Canada
(1.9 percent), or England (1.9 percent). Europe as a whole devotes 1.9 percent
to research and development, while industrialized nations spend around 2.3
percent.[x] If
one adds together all the science and technology workers in the United States
as a percentage of the workplace, 33 percent of American employees have science
or technology positions. This is slightly less than the 34 percent figure for
the Netherlands and Germany, but higher than the 28 percent in France and
Canada,.[xi] [ix] Michael Arndt: “Ben Franklin, Where Are You?” Business
Week, Jan.4, 2010, p. 29.
[x] Organisation for Economic Co-Operation and
Development, Science and Technology Statistical Compendium, 2004.
[xi] Organisation for Economic Co-Operation and
Development, Science and Technology Statistical Compendium, 2004.
Darrell
M. West and
Ashley Gabriele: Ten Leadrship Lessons from Simpson-Bowles, ; Governance
Studies. The Brookings Institution
, Nov, 2012.
[Weyzig:12]
Francis
Weyzig; “Tax Treaty Shopping: Structural Determinants of Foreign Direct
Investment Routed through The Netherlands”; Journal of International Tax and
Public Finance, 2012, Conduit function. Good bibliography.
[WeyzigD:09]
Francis
Weyzig and van Dijk: Incoherence Between Tax and Development Policies, The case
iof the Netherlands; Third World Quarterly, Vol.30 no.7 2009, p.1259-1277.;
[WGM:06] Gio Wiederhold, Amar Gupta, and Rajat Mittal: The
Value of Outsourced Software; in M.
Josef and B. Meyer (eds): Software Engineering Approaches for Offshore and
Outsourced Development (SEAFOOD), Springer Verlag Lecture Notes in Computer
Science, 2007, p.141-151; also Eller College of Management Working Paper No.1031-06,
University of Arizona - Eller College of Business and Public Administration, 14
May 2006. available at the Social Science Research Network, <http://ssrn.com/abstract=905148.
[WhiteC:11]
Kasdey Shewy White and Joanne P. Carney: Working with Congress, A Scientist’s
Guide to Policy; American Association for the Advancement of Science, 2011.
[WhittingtonD:12] O. Ray Whittington and Patrick R. Delaney: CPA Exam Reciew 2012; Wiley, 2012. On Kindle: Regulation volume. Also Finacial Accounting and Reporting; Auditing and Attestaion; Business Environment and Cocepts.
[Wicks:64]‡
[xls/irs]
[Wiederhold:09] Simon Wiederhold: Government
Spending Composition in a Simple Model of Schumpeterian Growth; 2009, Jena Research group on The Economics of Innovative
Change . (simon.wiederhold@uni-jena.de) (Friedrich Schiller University Jena, GK-EIC),
now in Munich.
[WilkinsD:12]‡
William J. Wilkins and Michael Danilack: Statement to Congress; Chief Counsel and Deputy
Commissioner (International) of the Large Business and International Division, Internal Revenue Service, Permanent Subcommittee on Investigations,
U.S. Congress, 20 Sep.2012. Transfer pricing is important, Requires substantial
enforcement resources. Aggressive income shifting. Temp regs finalized 2011. New hires, and new position Danilack. Focuss
on royalty payment. Core intangibles. Describes ex-ante income method. Only two cases litgated in last couple of
years. Bureaucratic answers. Mentions copyrights for high tech. Struggling with
intangible property rights. Riskyness is in the equation. No herky-jerky canges
to the tax law.
[WilliamsF:06] Jonathan Williams and Patrick Fleenor: Options for
Reforming the U.S. Corporate Income Tax; Fiscal Facts No.58, the Tax
Foundation, 8 May 2006. The 2005 Bush BAT plan. Problem of retained earnings.
[
[Wilson:97]†
Mike Wilson: The Difference Between Gods
and Larry Ellison; William Morrow Co., 1997.
[Wilson:89] James Q. Wilson: Bureaucracy; Basic Books, 1989. Updates [Weber:68]‡. Very
symphathetic and insightful. But simplifies the IRS’ situation.
[Wilson:99]‡
John D. Wilson: “Theories of Tax Competition”; National
Tax Journal 1999,
Vol.52, pp.269- 304.
[Wilson:05]‡
John D. Wilson: “Tax Competition with and without Preferential Treatment of a
Highly-Mobile Tax Base”; in J. Alm, J.
Martinez-Vazquez, and M. Rider (eds.): The Challenges of Tax Reform in
a Global Economy, Springer, 2005. From
<http://ideas.repec.org/a/kap/decono/v153y2005i3p277-301.html>.
[Wilson:06]‡
Fred Wilson: My favorite business model; AVC: musings of a VC in NYC, 23 Mar.
2006, http://avc.blogs.com/a_vc/2006/03/my_favorite_bus.html. On Freemium
Fred Wilson: Failure rates in early stage
venture deals; Union Square Ventures fund 29 Nov 07. 1/3 succesful, 10.2 leverage 1/3 even good deals,
average 2.6 lev/ 1/3 gone.
[Wilson:13] Wistar Wilson: Regulkating
the Virtual World: A Losing Battle; Reg Blog 11 Jul.2013, https://www.law.upenn.edu/blogs/regblog/2013/07/11-wilson-virtual-regulation.htm. Refers to thesis
worl of Gabroel [Michael:13] at GWU. Focus on file-sharing.
[WilsonB:01]‡ D. Mark Wilson and William
Beach: The Econmic Impact of President Bush’s Tax Relief Plan; The Heritage
Foundation Center for Data Analysis, Report #01-01, 27 Apr.2001. (revised from
22 Feb.2001). Would effectively pay off US national debt by FY2010.
Cites The UN General Assembly’s Commission of Experts on Reforms of the International Financial and Monetary System (the “Stiglitz Commission”) mentioned a financial services tax as a way of providing.more stable and sustainable development finance that.would also help to stabilize markets. The tax would be automatically collected at the exchanges and borne equally by buyers and sellers using the.electronic settlement systems. Between 0.01%-0.1%.
[WinnettK;12]
Robert Winnett and James Kirkup: 50p tax rate `failing to boost revenures’”; The Daily Telegraph, 21 Feb, 2012.
[Wipo:11]
About WIPO: What is Intellectual Property?; United Nations, World Intellectual
Property Organization, established 1967, Geneva,
<http://www.wipo.int/about-ip/en/, retrieved 2011.
[Wittendorf:] Jens
Wittendorff: Transfer Pricing and the Arm’s length Principle in International
Tax law; Kluwer. 2010. “If market imperfections in an industry make it
economically optimal to internalize a particular activity, then all things
being equal this will happen and associated enterprises will outperform
independent enterprises” (p.783). Only a casual mention of taxhavens.
[Woermann:13] Minaka
Woermann: On the (Im)Possibility of
Business Ethics; Springer Verlag, Issues in Business Ethics, No..37, 2013. Theory and
practice. Postmodern ethivs cannot be objective.
[Wolf:05] Martin Wolf: Why
Globalization Works; Yale Nota Bene, Yale University Press, 2005. Pp: 135-304Why the
critics are wrong , p 305-320. Corporate influence is less than made out to be,
(50/100 in list versus countries, ) but still significant 29/100?) . “Tax
havens are just termites”p.268. Admits
ignoring “The looming debate about the tradeability of Services”. Since people
don’t move assumes their IP does not move. Need world-wide taxation to overcome
effect of IP sales. Taxation and regulation p.252. The Internet is only 0.4%of GDP.
Depends on OECD data.
[Wolferman:11] Fred
Wolferman: How About a Zero Corporate
Tax?; The Pilot, North Carolina, 1
July 2011. Several
good comments as well.
[Wolff:09] Richard Wolff:
Capitalism Hits the Fan; http://www.youtube.com/watch?v=TZU3wfjtIJY>,
9 dec 2009. Economist,
author, Professor emeritus UMass, Amherst, Richard Wolff, speaks about the
current economic crises, its' roots and what we can do about it.
[Wolff:12] Richard Wolff: Democracy at Work, A Cure for Capitalism;
Haymarket books, 2012. Emainly traditiona Marxist arguments. Suggestion is that
Worker’s Self-Directed Enterprises (WSDEs) should replace trdional corporations,
maybe starting with businesses that fail. Have.
[Wolverson:11]‡ Roya Wolverson:
Outsourcing Jobs and Taxes; Renewing America, Council on Foreign
Relations, 11 Feb.2011. Several good
comments as well.
[[WSJ:11]
Review and Outlook: The Corporate Welfare State; WSJ, 8 Nov 2001, page 14. 2008 Cato Inst
estimate $93B in 2006. $6B for ethanol/year. Comments favor Zero Corp tax.
[H.R. 25, the FairTax proposal; U.S Congress, 6 Jan.2011. Originally
introduced in 1999 by John Linder. Quotes the National Commission on Economic
Growth [xls/taxes]
[
<http://www.bus.umich.edu/otpr/otpr/default.asp
-existing intangible property acquired in an acquisition available to a CSA.
Distribution of Permanent Reinvested Earnings";
[Wydick:08] Bruce Wydick:Games in Economic Development ; Cambridge
University Press, 2008. On Kindle It has math. But it is written simply and clearly and
the math is confined to specific sections. You can easily skip the math and
fully benefit from this book. It is not just a book about economic development,
but rather a book about markets that are (1) out of equilibrium, and (2) with
poorly defined and enforced property rights. But to some degree that is true of
all markets and this perspective takes you deep into the foundations of both
capitalism and civilization. Incredibly sophisticated. Reinforces many of these
lessons and teaches many more. Ultimately culture is what matters more than
markets or government.
[WydenG:10]
Wyden and Greg: tax reform: exclude 2nd residences, home equity
loans, and mortgages over $500,000. See BowlesS10 draft slides. Permanent tax credit
eliminate domestic production , LIFO accounting, oil and gas, change
depreciation. Territorial tax.
[
[Yamamura:12] K.
Yamamura: Changing corporate tax rules; Sacramento
Bee, 15 Oct.2012.
[YoungV:11] Christobal
Young and Charles Varner: Millionaire Migration and State Taxation of Top
Incomes: Evidence from a Natural Experiment; National Tax Journal, Jun2011, Vol.64 no.2, part 1, pp.255–284. People stay put
[Zadrony:06]
Wlodek Zadrony: "Leveraging the Power of Intangible Assets"; MIT
Sloan Management Review, Vol48. No.1, Fall 2006, reprint #48117. Ignores
Software, but cites that info is in corporate DBs and can be mined. In
TT-IP/worth references.
[Zeidman:11] Bob Zeidman: The Software IP Detective's Handbook,
Measurement, Comparison, and Infringement Detection; Prentice Hall, Pearson
Publishing, 2011.
[Zembar:11]
Tom Zembar: When corporations avoid paying Taxes, public education gets
shortchanged; National Education Association, 7 Nov.2011.
[Zheng:]
Tracey Zheng: Overview of Transfer Pricing Guidelines; Chapter 11 in William kastner, Doing Business in
Washington State.>
[Zima:07]
Patricia Zima, Mohawk College: “Goodwill and Other Intangible Assets; Chapter 12 in: Intermediate Accounting, 8th ed; Wiley Canada, 2007.
[Zipf:49]† George K. Zipf: Human
Behavior and the Principle of Least Effort; Addison-Wesley, 1949.
Ahmed Zoromé: Concept
of Offshore Financial Centers: In Search of an Operational Definition;
International Monetary Fund, IMF Working Paper/07/87, <http://www.imf.org/external/pubs/ft/wp/2007/wp0787.pdfl> . An OFC
is a country or jurisdiction that provides financial services to nonresidents
on a scale that is incommensurate with the size and the financing of its
domestic economy.