Tax Analysts Blog

Monday, June 3, 2013
One part of the TIGTA report that has received scant attention in the press or during congressional hearings is its findings on the accuracy of the selection process used by the IRS to identify potential political cases. For a period of time, the IRS used name-based and policy-based criteria to sel...
Tuesday, May 28, 2013
The Treasury Inspector General for Tax Administration's report that is at the center of the current firestorm over potential political bias at the IRS asserts that the IRS used “inappropriate criteria” to choose applications for tax exempt status that would be subject to further review. These cr...
Monday, May 20, 2013
Tomorrow there will be two Senate hearings on taxation. The first is the Senate Finance Committee hearing on IRS inappropriate targeting of conservative groups applying for 501(c)(4) status. Although discrimination based on political belief is a serious problem, qualification for 501(c)(4) status i...
Monday, May 13, 2013
At the behest of the G20 the OECD has launched a major effort to limit profit shifting by multinational corporations. Some in the U.S. have expressed concern that this OECD "BEPS" (base erosion and profit shifting) initiative has been motivated by foreigners and their governments' desire to bash U...
Monday, May 6, 2013
Although the formal expiration of the debt limit is May 19, the ability of the Treasury Department to juggle some internal accounts is likely to extend the effective deadline until late summer. Nothing is certain, but the real deadline is likely to crop up in September or even October. This sets th...
Monday, April 29, 2013
Sometimes it is said all philosophy is a footnote to Plato. Perhaps it should also be said that all political satire is a footnote to the Irish clergyman Jonathan Swift. In his many works, Swift unmercifully challenges the status quo with unsurpassed wit and humor. Though they have just as much raw...
Monday, April 22, 2013
In international tax, determining whether the price is right is everything. A multinational can save hundreds of millions of dollars in tax by “selling” foreign rights to its intellectual property (IP) to a wholly-owned subsidiary in a tax haven. The key to success for a multinational is getting...
Monday, April 15, 2013
I was wrong. I thought that The Organisation for Economic Co-operation and Development (OECD) had shrugged off its cautious, conservative tendencies with the issuance of its February 12 report entitled "Base Erosion and Profit Shifting." After my first read of the 91-page document I believed the OE...
Monday, April 8, 2013
Suppose the state police want to crack down on speeding, which the public is complaining has become rampant. But the police have a problem with enforcement. Some savvy entrepreneur has developed an anti-radar gun that blocks the ability of radar guns to measure speed. And separately, a court has ru...
Monday, March 25, 2013
In recent years U.S. multinationals have restructured themselves in a manner that allows them to greatly reduce their worldwide tax bill. This restructuring has been described in detail by the OECD andil and by the Joint Committee on Taxation. In a March 15 presentation at a conference on taxation...
Monday, March 18, 2013
Vivid press reports of U.S. companies not paying their fair share of tax in the United Kingdom has motivated the Conservative-led government to take the lead on coordinating international efforts to curb aggressive tax avoidance. The last time the U.S. public got upset about foreign corporations no...
Monday, March 11, 2013
"In case there is any doubt I want you to know we will preserve the part of the American dream which the home mortgage interest symbolizes." -President Ronald Reagan to realtors, 1984 Founded in 1872 on the Santa Fe Trail and the Atchison, Topeka & Santa Fe Railroad, Dodge City--"the Cowboy Capita...
Monday, March 4, 2013
Equipment vs. buildings. One of the long-standing debates in tax economics is whether or not investment incentives should be tilted in favor of equipment -- and, by implication, because of its disproportionate investment in equipment—manufacturing. The basic idea is that equipment investment is cl...
Friday, March 1, 2013
In the United Kingdom a great debate is taking place about aggressive tax avoidance. On one side, David Cameron, the Conservative prime minister, says it is immoral. On the other side, most executives say they have a duty to their shareholders, and most practitioners say they have a duty to their c...
Monday, February 18, 2013
By closing some additional loopholes through tax reform — which Speaker Boehner has acknowledged can raise money in a sensible way — and by doing some additional cuts . . . we can arrive at a package that gets this thing done. --President Obama, Jan. 14 The President got his tax increases last ye...
Friday, February 15, 2013
This week a lot of very smart people gathered at the Ritz-Carlton in Washington DC for a two-day conference on tax issues related to the taxation of patents, trademarks, know-how and all other types of intellectual property ("intangibles" in tax speak). If you think this an obscure topic let me put...
Monday, February 11, 2013
Fresh from the Democratic retreat in Leesburg Virginia, Rep. Chris Van Hollen of Maryland, ranking member on the House Budget Committee, appeared in a C-Span interview this weekend. Twice he repeated the line we have heard recently from other Democratic leaders--including President Obama and New Y...
Friday, February 8, 2013
"Talk doesn't cook rice." -Chinese Proverb Has anybody else noticed the new fad in tax policy? Whet the public's appetite and grab headlines with a lot of loud and happy talk about your intent to dramatically cut tax rates. And then mumble some vague notions about ways to pay for those cuts. Mitt...
Monday, February 4, 2013
Tomorrow the Congressional Budget Office will release its semi-annual Budget and Economic Outlook. The report will provide the economic and budget projections that will be the basis of the contentious budget debate that will take place over the next few months. What may be surprising to some is tha...
Friday, February 1, 2013
In a cramped and drab committee room four highly-compensated tax partners from the world's largest accounting firms looked like they would rather be mopping floors than answering the questions of Committee Chair Margaret Hodge. The senior UK legislator did a good job of expressing the frustration o...