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Taxes, Spending, And Innovation, Michael Simkovic 2019 USC Gould School of Law

Taxes, Spending, And Innovation, Michael Simkovic

University of Southern California Legal Studies Working Paper Series

Part I: Billionaire Taxes, https://ssrn.com/abstract=3326615.

Part III: After Paying Ultra-High Net Worth Wealth Taxes, How Much Would Billionaires Have Left to Live on?, https://ssrn.com/abstract=3340925.

Key Takeaways:

- Innovation is the product of teamwork.

- Engineers and scientists play a critical role.

- Scientific research is insufficiently rewarded financially.

- Taxes can boost innovation by funding human capital investment and basic research.

- The amount of investment is important – who owns financial assets is not.

In formulating taxation and public investment policies, we should carefully consider data and the peer reviewed literature. Claims that we can drive more ...


After Paying Ultra-High Net Worth Wealth Taxes, How Much Would Billionaires Have Left To Live On?, Michael Simkovic 2019 USC Gould School of Law

After Paying Ultra-High Net Worth Wealth Taxes, How Much Would Billionaires Have Left To Live On?, Michael Simkovic

University of Southern California Legal Studies Working Paper Series

Part I: Billionaire Taxes, https://ssrn.com/abstract=3326615.

Part II: Taxes Spending and Innovation, https://ssrn.com/abstract=3335386.

How much can a passive investor with a high-risk tolerance earn on his or her capital?

If history since the end of World War 2 is any guide, between 11 and 14 percent per year before taxes and inflation. After inflation, this comes to around 7 to 10 percent. With good tax planning, the rate of return net of income taxes, inflation, and fees could average around 6.5 to 9.5 percent per year.

A family with $100,000 ...


Free Money, But Not Tax-Free: A Proposal For The Tax Treatment Of Cryptocurrency Hard Forks, Danhui Xu 2019 Fordham University School of Law

Free Money, But Not Tax-Free: A Proposal For The Tax Treatment Of Cryptocurrency Hard Forks, Danhui Xu

Fordham Law Review

Cryptocurrency has attracted extraordinary attention as one of the greatest financial innovations in recent years. Equally noticeable are the increasingly frequent cryptocurrency events, such as hard forks. Put simply, a cryptocurrency hard fork happens when a single cryptocurrency splits in two, which results in original coin owners receiving free forked coins. Such hard forks have resulted in billions of dollars distributed to U.S. taxpayers. Despite ongoing regulatory efforts, to date, the Internal Revenue Service (IRS) has yet to take a clear position on the tax treatment of cryptocurrency hard forks. The lack of useful guidance when filing tax returns ...


United States Policy And The Taxation Of International Intangible Income, Stanley I. Langbein 2019 University of Miami School of Law

United States Policy And The Taxation Of International Intangible Income, Stanley I. Langbein

University of Miami Inter-American Law Review

No abstract provided.


Taxing The Robots, Orly Mazur 2019 SMU Dedman School of Law

Taxing The Robots, Orly Mazur

Pepperdine Law Review

Robots and other artificial intelligence-based technologies are increasingly outperforming humans in jobs previously thought safe from automation. This has led to growing concerns about the future of jobs, wages, economic equality, and government revenues. To address these issues, there have been multiple calls around the world to tax the robots. Although the concerns that have led to the recent robot tax proposals may be valid, this Article cautions against the use of a robot tax. It argues that a tax that singles out robots is the wrong tool to address these critical issues and warns of the unintended consequences of ...


Bearing Hospital Tax Breaks: How Non-Profits Benefit From Your Surprise Medical Bills, Taylor N. Armstrong 2019 Georgia State University College of Law

Bearing Hospital Tax Breaks: How Non-Profits Benefit From Your Surprise Medical Bills, Taylor N. Armstrong

Georgia State University Law Review

This Note addresses the growing issue of surprise medical bills and how the United States Tax Code can be used to prevent many patients from receiving these bills. Part I provides a background on surprise billing and market factors that have led to an increase in the bills as well as current legislative solutions to the problem. Part II analyzes the role that hospitals play in the insurance market, the current standards for nonprofit hospitals to receive tax exemption under Internal Revenue Code (IRC) § 501, and how these legal standards fall short of accomplishing the goals of the tax exemption ...


The Tcja And The Questionable Incentive To Incorporate, Part 2, Michael S. Knoll 2019 University of Pennsylvania Law School

The Tcja And The Questionable Incentive To Incorporate, Part 2, Michael S. Knoll

Faculty Scholarship at Penn Law

The Tax Cuts and Jobs Act (TCJA) has put the question should a business be organized as a passthrough entity or as a corporation at center stage. The TCJA eliminated much of the tax disadvantage from using the corporate form, but did Congress go so far that it advantaged corporations relative to pass-through entities? Some prominent commentators say yes. They argue that the federal income tax now encourages individual owners of pass-through businesses to restructure their business as subchapter C corporations, and they predict that the TCJA will lead to a cascade of incorporations. The principal driver of the shift ...


Cooper V. Commissioner: Give The Inventor A (Learned) Hand, Rebecca R. Dulik 2019 University of Maine School of Law

Cooper V. Commissioner: Give The Inventor A (Learned) Hand, Rebecca R. Dulik

Maine Law Review

Among the Internal Revenue Code’s many rules are some taxpayer-friendly provisions that grant tax benefits. Section 1235 is one such provision, providing to an inventor preferential tax treatment for income from the sale or exchange of a patent. In Cooper v. Commissioner, although the taxpayer inventor satisfied § 1235’s requirements, the Ninth Circuit affirmed the Tax Court’s decision to deny the taxpayer § 1235’s benefits. This Note compares Cooper to other § 1235 cases and argues that Cooper was decided wrongly because of the application of the substance over form doctrine. The substance over form doctrine is overapplied in ...


The Tcja And The Questionable Incentive To Incorporate, Michael S. Knoll 2019 University of Pennsylvania Law School

The Tcja And The Questionable Incentive To Incorporate, Michael S. Knoll

Faculty Scholarship at Penn Law

The Tax Cuts and Jobs Act (TCJA) has put the question should a business be organized as a passthrough entity or as a corporation at center stage. The TCJA eliminated much of the tax disadvantage from using the corporate form, but did Congress go so far that it advantaged corporations relative to pass-through entities? Some prominent commentators say yes. They argue that the federal income tax now encourages individual owners of pass-through businesses to restructure their business as subchapter C corporations, and they predict that the TCJA will lead to a cascade of incorporations. The principal driver of the shift ...


Taxing Selling Partners, Emily Cauble 2019 University of Washington School of Law

Taxing Selling Partners, Emily Cauble

Washington Law Review

When a partner sells a partnership interest, the resulting gain or loss is treated as capital gain or loss, except to the extent that the partnership holds certain items whose sale would result in gain or loss that was not capital. Seemingly, the purpose of this regime is to prevent taxpayers from obtaining more favorable treatment by selling an interest in a partnership than what would result if the partnership were to sell its underlying assets. But given this legislative aim, the existing tax provisions produce results for taxpayers that are both unduly favorable (in that sale of a partnership ...


Billionaire Taxes, Michael Simkovic 2019 USC Gould School of Law

Billionaire Taxes, Michael Simkovic

University of Southern California Legal Studies Working Paper Series

Targeted ultra-high net worth wealth taxes can fund reductions in taxes on wages. Wealth taxes are harder to avoid than existing capital gains taxes and inheritance taxes, and can be more precisely targeted toward extreme wealth. Exit taxes to prevent capital flight are consistent with business law principles governing partnerships. Valuation disputes can be managed through existing property tax mechanisms and through private law provisions called "shotgun clauses."

Most experts believe that wealth taxes are constitutional. The critical difference between wealth taxes and income taxes, the realization requirement, exists for administrative convenience, not as a constitutional requirement. Constitutional challenges can ...


The Contemporary Tax Journal’S Interview With Eileen Marshall, Rani Vaishnavi Kothapalli 2019 San Jose State University

The Contemporary Tax Journal’S Interview With Eileen Marshall, Rani Vaishnavi Kothapalli

The Contemporary Tax Journal

No abstract provided.


Roger Cpa Review, Roger Philipp CPA, CGMA 2019 San Jose State University

Roger Cpa Review, Roger Philipp Cpa, Cgma

The Contemporary Tax Journal

No abstract provided.


Section 1031 Like-Kind Exchange, Daniel Currie 2019 San Jose State University

Section 1031 Like-Kind Exchange, Daniel Currie

The Contemporary Tax Journal

No abstract provided.


Section 195, Luis Rodriguez Jr., MBA, JD, LLM 2019 Alfred University

Section 195, Luis Rodriguez Jr., Mba, Jd, Llm

The Contemporary Tax Journal

No abstract provided.


The Contemporary Tax Journal Volume 8, No. 1 – Winter 2019, 2019 San Jose State University

The Contemporary Tax Journal Volume 8, No. 1 – Winter 2019

The Contemporary Tax Journal

No abstract provided.


Short Sales And Cancellation Of Debt Income, Rani Vaishnavi Kothapalli 2019 San Jose State University

Short Sales And Cancellation Of Debt Income, Rani Vaishnavi Kothapalli

The Contemporary Tax Journal

No abstract provided.


Taxation Of Cryptocurrency Hard Forks, Rachana Khandelwal 2019 San Jose State University

Taxation Of Cryptocurrency Hard Forks, Rachana Khandelwal

The Contemporary Tax Journal

No abstract provided.


Tax Treaties And Special Considerations For Unemployment Income, Foreign Students, And Academic Employees, Inna Ostrovsky 2019 San Jose State University

Tax Treaties And Special Considerations For Unemployment Income, Foreign Students, And Academic Employees, Inna Ostrovsky

The Contemporary Tax Journal

No abstract provided.


Summaries For The 6th Annual Irs-Sjsu Small Business Tax Institute, Daniel Currie, Ruchi Chopra, Chen Chen, Sara Yaqin Sun, Surbhi Doshi, Tina Tran 2019 San Jose State University

Summaries For The 6th Annual Irs-Sjsu Small Business Tax Institute, Daniel Currie, Ruchi Chopra, Chen Chen, Sara Yaqin Sun, Surbhi Doshi, Tina Tran

The Contemporary Tax Journal

No abstract provided.


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