Die Abhandlung ist eine überarbeitete und erweiterte Fassung der vom Institute for Monetary and Financial Stability am 19. Juni 2006 veranstalteten Guest Lecture des Autors zum Thema "Demystifying Hedge Funds"

Die Abhandlung ist eine überarbeitete und erweiterte Fassung der vom Institute for Monetary and Financial Stability am 19. Juni 2006 veranstalteten Guest Lecture des Autors zum Thema Demystifying Hedge Funds

This article briefly traces the history of tax sheltering in the latter half of the twentieth century in the United States, including the transformation of the role of tax professionals from support functions in tax planning for transactional efficiency to profit center functions through...

Demonstrates that there is no tax savings to be achieved by using a trust to restrict a donee's control of property and money transferred gifts during life or at death. Reviews reasons why donors wish to continue to control wealth even after death and suggests that such reasoning is fallacious....

The United States derives from a global income tax model under which it taxes it citizens and permanent residents on all their worldwide income without regard to the source of that income. Under a pure global model, the United States would combine income and deductions in a single tax...

Taxpayers shift income offshore with lawful devices like operating through a foreign corporation. Taxpayers have enhanced the amount of that income lodged outside the U.S. with transfer pricing strategies. And taxpayers have evaded U.S. taxation of their worldwide income by secreting assets and...

International corporate tax competition continues to exert pressure on legislatures to reduce corporate tax rates as well as the rate imposed on shareholders. To combat this pressure, this commentary recommends eliminating the corporate income tax. Instead corporations should become tax...

To preserve social security as a welfare program primarily for older individuals and to ameliorate the distributional inequity of funding social security across income and wealth levels, this article recommends unbundling the benefit side of social security from its longstanding payroll tax...

With emphasis on the US, this chapter explores the role that taxation plays in the movement of people and capital. The chapter addresses the relationship between taxes and retention of capital, including tax incentives for capital investment, shifting tax burdens from capital to labor as...

Critical tax theory identifies systemic imbalances in taxation that impose disproportionally high tax burdens on groups who lack or fail to exercise political power. This article focuses on foreigners as an ideal taxpaying group because it does not vote. The article identifies some ways in which...