Obama can increase the tax on carried interest unilaterally
My latest Dealbook column: President Obama could change the tax treatment of carried interest with a phone call to the Treasury Department. But the White House will need a precise understanding of the...
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How Tax Laws Distort the Pfizer Deal
But the clearest distortion is not size, but location. For multinational corporations based in the United States, taxes create an incentive to expand overseas operations by opening foreign...
View ArticleTaxes Won’t Kill Bitcoin, but Tax Reporting Might – NYTimes.com
My take on the bitcoin guidance: Bitcoin is a digital representation of value, not a real currency, according to the latest pronouncement from the Internal Revenue Service.The I.R.S. on Tuesday...
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Baucus Cost Recovery Proposal
A tax proposal released on Thursday by the chairman of the Senate Finance Committee, Max Baucus, addresses a topic that tends to make my students’ eyes glaze over: cost recovery.Cost recovery is a...
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Baucus International Tax Proposal
Changes to the tax code always create winners and losers. An ambitious plan to revise the system for taxing multinational corporations, released on Tuesday by the Senate Finance Committee chairman, Max...
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An Offbeat Merger
Other methods of tax avoidance have received less news media attention but are no less troubling. A recent deal by LIN Media, a media company backed by the private equity firm HM Capital Partners and...
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Why Twitter May Have to Pay Income Taxes One Day – NYTimes.com
Potential investors in Twitters’s planned initial public offering may be struggling to estimate how much the company will have to pay in taxes in the future. An article in Politico on Friday...
View ArticleA Holiday From Taxes
Large multinationals based in the United States – among them General Electric, Pfizer, Apple and Citigroup – have been hoarding record amounts of cash overseas, mainly because of the 35 percent tax...
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Bezos’s acquisition of Wa Po
Jeff Bezos’s purchase of The Washington Post raises the possibility that he acquired the paper as a trophy to celebrate his success as the founder and chief executive of Amazon.com. The acquisition...
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Pension Reform Could Disrupt Investment Funds
Detroit’s financial woes, exacerbated by underfunded pension liabilities, have brought renewed scrutiny to public pension plans. Senator Orrin Hatch, Republican of Utah, and others have suggested...
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Sun Capital Court Ruling Threatens Structure of Private Equity – NYTimes.com
Last week, the United States Court of Appeals for the First Circuit issued a ruling that will make it harder for private equity funds to walk away from the unfunded pension liabilities of companies...
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MLPs: how the IRS subsidizes oil and gas
My column on how the IRS ruling policy on master limited partnerships subsidizes oil and gas: How the I.R.S. Encourages Oil and Gas Spinoffs – NYTimes.com. The grand bargain of the landmark tax...
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Defining REITs
[From my latest NYT column. I plan to do a related column on energy MLPs soon.] Shares of the information storage company Iron Mountain dropped about 15 percent last week on the news that the I.R.S....
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Economic Roots of Apple
My take on the Apple hearing: The hearing by the Senate Permanent Subcommittee on Investigations on Tuesday focused on Apple‘s shifting of offshore profits. Apple’s tax planning stems from an almost...
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Reducing the Corporate Tax Rate Could Stabilize Banks – NYTimes.com
In the paper, the authors look at statutory tax rate changes over a 12-year period in 87 countries to see how those rate changes affected banks’ capital structure. They find that a 10 percentage point...
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Apple’s True U.S. Tax Rate
Here’s my suggestion. Congress should require every large American company to disclose to the public a simple number each year, which I would call the “true U.S. tax rate”: (1) the amount of cash tax...
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Despite Tax Rules, Companies Stick With U.S
Because corporate residence is, in effect, elective, it is surprising that nearly all new companies with headquarters here elect to incorporate in the United States and pay tax here. Two new papers...
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The Top 10 Private Equity Loopholes – NYTimes.com
The Top 10 Private Equity Loopholes By VICTOR FLEISCHER Happy Tax Day. April 15 is a good day to reflect on how much you pay in taxes and what you receive in return. It’s also good to think about how...
View ArticleMy take on partnership tax reform
Incremental change with a minimum of controversy must be Mr. Camp’s goal. That would explain why he takes the corner wide, steering clear of the most controversial aspect of partnership tax: carried...
View ArticleLynnley Browning on Supercharged IPOs
Lynnley Browning has a story in today’s NYT about Supercharged IPOs, drawing in part on my study with Nancy Staudt. “They involve millions, often billions, of dollars in cash transfers from newly...
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