While the federal and state income taxation of regular sole proprietorships and single member LLCs taxed as sole proprietorships and the taxation of the owners of such businesses is substantially the same, there are a number of tax and non-tax differences that should be taken into account in...

Estate planners undertake various strategies to minimize estate taxes and income taxes of the estate and beneficiaries with respect to property received from the estate. A tax planning strategy that can significantly reduce income taxes of the estate and/or its beneficiaries is to structure the...

Reform of the U.S. international tax policy is under consideration in Congress. Policymakers are concerned with both reducing tax disincentives to repatriate earnings to the U.S. and with constraining business tactics to move U.S. income offshore. We argue that to achieve significant tax reform,...

Firms that lobbied for the tax holiday for repatriations provided under the American Jobs Creations Act of 2004 were the largest beneficiaries of the provision. They repatriated an average of over $4 billion under the Jobs Act. Although firms that lobbied for the tax holiday repatriated large...

Recent theoretical research suggests that among U.S. firms that have reached their optimal level of investment in foreign operations some will be induced by the U.S. repatriation tax system to accumulate foreign earnings in foreign financial assets. In this paper we evaluate this behavior which...

Under the current U.S. tax system, corporations have an incentive to defer the repatriation of their foreign earnings. This incentive is commonly referred to as the lock-out effect. The lock-out effect is significant, as estimates indicate that U.S. corporations hold nearly $2 trillion of...

The American Jobs Creation Act (AJCA) of 2004 provided a one-time tax holiday for firms to repatriate foreign earnings. AJCA was intended to stimulate the economy by expediting the repatriation of foreign earnings and requiring that those repatriations be invested in domestic operations. This...

This article evaluates the benefits of converting to the Roth IRA during a depressed market and supports the adage that “every cloud has a silver lining”. Although taxpayers have watched the value of their retirement savings dwindle this year, it has created an opportunity for taxpayers to...