Drucker on Romney’s Gift Tax Avoidance
While Romney’s tax avoidance is both legal and common among high-net-worth individuals, it has become increasingly awkward for his candidacy since the disclosure of his remarks at a May fundraiser. He...
View ArticleRise of the General Counsel
In a special New York Times section on business and law, Andrew Ross Sorkin opines: “As regulations change and the threat of litigation rises, the importance of lawyers has never been greater.” He, and...
View Article11 Debate Questions for Romney on Taxes | Mother Jones
Your severance agreement with Bain Capital has paid you millions of dollars for the services you performed at Bain. Did you pay the Medicare tax on those amounts, and if not, why not? via 11 Debate...
View ArticleGetting comfortable with tax evasion
The legality of this loan program is questionable. In similar cases, the Internal Revenue Service has successfully argued that a series of short-term loans should be recast as what it is in substance:...
View Articlethe mindset of a financier president
Thoughtful article by an experienced PE investor: Romney’s financial success is admirable and enviable, but it came by following the mantra of increasing cash flow, cutting jobs and minimizing taxable...
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Romney is pretty slippery on tax valuation
The transcript of Romney’s testimony about Staples is pretty interesting. Romney told the truth under oath, as best I can tell, but not when it came to reporting the true value of common stock for tax...
View ArticleOn failed REMICs
My latest column: The Wall Street Rule is objectionable from a tax policy perspective when aggressive tax lawyers sanction a deal structure that contravenes the rules, or one that resides in a gray...
View Articledon’t hold your breath on lower corporate tax rates
Many companies use tax planning to create a competitive advantage. If your competitors pay taxes at a 35 percent rate, but you have figured out a way to greatly reduce your effective tax rate, then the...
View Articlethe angel investor tax loophole
From my column today: Consider the special provision for “qualified small business stock,” which provides a zero percent tax rate on capital gains from certain investments. A better name would be the...
View Articlemark to market for derivatives
Representative Dave Camp, the Michigan Republican and chairman of the House Ways and Means Committee, recently released a discussion draft of proposed legislation that would tax most financial...
View Articlemy take on the tax benefits of working at work
Yahoo’s chief executive, Marissa Mayer, inspired much debate and rebuke when she recently abolished Yahoo’s work-at-home policy. In academia, “working from home” is a treasured euphemism for heading...
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...
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...
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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...
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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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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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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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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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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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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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