References - Stanford Universityinfolab.stanford.edu/pub/gio/CS207/VICcitations.pdf · corporate income is the price of that protection. This price must be worth the benefits since,

References

References for Gio Wiederhold:

Valuing Intellectual Capital, Multinationals and Taxhavens

Springer Verlag 2012

HMAT Citations

This list includes all the references cited. For general information, I chose a recent publication, trusting that it will be easier to locate and cite earlier work. As is common in tax matters, opinions abound. Refereed material is italicized. A secondary list, available on the web, provides further references.

References marked with a † (are (currently) not cited and should be culled. Shaded text to be omitted in publication.

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[AbahoonieA:10] Edward Abahoonie and Liah Alfonso: Deferred Taxes on Foreign Earnings: A Road Map; Price Waterhouse Coopers (PWC), Dec.2010.

[AbramitzkyB:04] Ran Abramitzky and Fabio Braggion: Malthusian and Neo-Malthusian Theories; Oxford Encyclopedia of Economic History, Oxford University Press, 2004. At Stanford University.

[ADLittle:85] ADLittle: Development of a Methodology for Estimating the Taxpayer Paperwork Burden; IRS, June 1988. Time cost for individual and Tabusiness taxpayer 1813M, 3,614 = total 5,427M hours.

[AF:04] The Appraisal Foundation: Uniform Standards of Professional Appraisal Practice; Standard 9, 2004 Edition.

[Aiken:09] Alex Aiken: Measure of Software Similarity software; MOSS software, 2009,

countries like Germany, where Chancellor Angela Merkel must justify why taxpayers should help pay for another bailout package. The argument is that Ireland could be collecting more money from the companies it has lured. /Tax rates have become a contentious issue in Europe, where governments are competing as never before to lure badly needed foreign investments as the economic crisis weighs on growth.

[AlmDM:04] James Alm, John Deskins, And Michael McKee: Tax Evasion and Entrepreneurship: The Effect of Income reporting Policies on Evasion; 97th Annual Conference of the National Tax Association, Minneapolis, MN, Nov.2004. An audit rate of 10 vs 30% doubles non-compliance.

[Almeida:04] Aloisio Almeida: Tax Havens: An Analysis of the OECD Work with Policy Recommendations; Ford School of Public Policy, Apr.2004. 5 uncoopartive jurisdiections: Andorra, Liberia, Liechtenstein, Monaco, Marshall Islands. Thjtree were removed in 2000: Barbados, Maldives, Tonga, 33 will fix ttransparency.

[Alter:11] Jonathan Alter: Coming Lobbyist Brawl May (Really) Fix Our Taxes; Bloomberg Businessweek, 5 Aug 2011. the author of “The Defining Moment: FDR’s Hundred Days and the Triumph of Hope” . On the supercommittee’s chances.

[AltshulerACK:08] Rosanne Altshuler, Alan J. Auerbach, Michael Cooper, and Mathew Knittel: Understanding U.S. Corporate Tax Losses; NBER Tax Policy and the Economy Conference, Washington, DC, 6.Oct.2008. Tax expenditures , Many Graphs. Uses form 1120 data. Cooper and Knittel are with the Treasury.”...taxpayers can engage in .excessive. or in some other way unintended use of legal tax provisions to reduce tax liabilities.”

[AltshulerM:06] Rosanne Altshuler and Jack M. Mintz: “United States Interest-Allocation Rules, Effects and Policy”; in [Slemrod:96] .

[AltshulerHT:10] Rosanne Altshuler, Benjamin Harris, and Eric Toder: “Capital Income Taxation and Progressivity in a Global Economy”; Virginia Tax Review, Vol. 30, Fall 2010, pp.355-388. Tax gains at 28% and dividends fully yields $87B to reduce corporate tax from 35% to 26%.

[Amadi:02] Confidence W. Amadi: Double Taxation of Dividends: A Clarification

9-Dec-11 HMAT ©Gio Wiederhold

[Anderson:09] Eric Anderson: Take the Money and Run, Sovereign Wealth Funds and the Demise of American Prosperity; Praeger Security International, 2009. Stanford Library checkout, bought it later. Focus on Souvereign wealth funds, in the city.. chap 5 merger rules, Chap 6 on tax 2008 plans

[AngusNSW:10] Barbara Angus, Tom Neubig, Eric Solomon, and Mark Weinberger: “The U.S. International Tax System at a Crossroads”; Tax Analysts, E&Y, 2010. Companies will invest if taxed more. Tables of Fortune 500 global companies. importance of intangibles and services. “Changes to the international tax rules should not be undertaken piecemeal.”

[AP:11] AP: Western Union to Pay $220M More in IRS Settlement; Associated Press, Bloomberg Businessweek, 15 Dec.2011.

[Arellano:08] Sergio Arellano : Exit Strategies; IRS, 2002, . Starting 1999 to 2006 US company with a Possessions corporation transfer assets as a non-taxable contribution (Sect.351) or non-taxable reorganization (sect.361) to a CFH in Bermuda or so. The Puerto Rico operation becomes a subsidiary of the CFH. “A taxpayer may claim that transfers from the § 936 corporation include a significant amount of value in the form of workforce-in-place and that such workforce-in-place is not taxable. Workforce-in-place is properly treated as an intangible under § 936(h)(3)(B), and is therefore taxable under § 367(d). Some taxpayers have argued that the workforce-in-place is a part of going concern value that transfers tax free to the foreign corporation. However, to the extent that workforce-in-place can be identified and valued as a distinct asset, workforce-in-place should not be viewed as part of foreign goodwill or going concern value. ”.

[Argy:06] Victor Argy: The Postware International Money Crisis: An Analysis; Taylor and Francis, 1981, reprinted 2006 by Routledge. Eurodollar reserves 1976, 222.1B SDR. 485 per Morgan Guarantee

[ASCAP:10] The American Society of Composers, Authors and Publishers: Customer licensees; ASCAP, 20101,

[Asher:09] Mukul G Asher: Needed, a more comprehensive approach to tax havens; Daily News & Analysis (DNA), 9 May 2009.

[Asher:09] Mukul G Asher: Needed, a more comprehensive approach to tax havens; Daily News & Analysis (DNA), 9 May 2009.

[Ashley:10] Sophie Ashley: “Ireland increases withholding tax exemption”; International Tax Review, 01 Nov.2010.

[AsprayMV:06] William Aspray, Fred Mayadas, and Moshe Y.Vardi (eds.): Globalization and Offshoring of Software; A Report of the ACM Job Migration Task Force, ACM, 2006.

[Atkinson:11] Robert D. Atkinson: U.S. Corporate Tax Reform: Groupthink or Rational Debate?; The Information Technology & Innovation Foundation, Washington DC (ITIF) report, July 2011, .

[Atwood:08] Margaret Atwood: Payback (Debt and the Shadow Side of Wealth); Anansi, Toronto, 2008.

[Audretsch :95] David B. Audretsch: Firm profitability, growth, and innovation; Review of Industrial Organization, Vol.10, no.5, 1995, pp.579-588. Lag is 4.2 years , leverage for innovatve industries 2.563, for innovative computer companies 4.525.

[Auerbach:99] Alan J. Auerbach: “Measuring the impact of tax reform”; in [Slemrod:99], p.360 . Making incremental changes is more effective than grand ones.

[AuerbachF:02] Alan J. Auerbach and Martin Feldstein, eds.: Handbook of Public Economics, Vol. 4, North-Holland, 2002.

[Auerbach:06] Alan Auerbach: Why have Corporate Tax Revenues Declined” Another Look; CESifo workshop, The Future of Capital Income Taxation, Venice, July 17-18, 2006, updated Dec.2006. Ignores effect of AJCA.

[Auerbach:05] Alan Auerbach: Who Bears the Corporate Tax, A Review of What we Know; NBER’s Tax Policy and the Economy conference, Sep.2005. Different sizes of corporations, shareholders, and timing.

http://www.irs.gov/businesses/article/0,,id=179270,00.htmlhttp://www2.itif.org/files/2011-corporate-tax-reform.pdfhttp://www.springerlink.com/content/?Author=David+B.+Audretschhttp://www.springerlink.com/content/q26763455628333h/http://www.springerlink.com/content/0889-938x/http://www.springerlink.com/content/0889-938x/http://www.springerlink.com/content/0889-938x/10/5/

[Aujean:01] Michel Aujean (chair): Company Taxation in the Internal Market; Commission of the EC, 23 Oct 2001. Includes problems with Transfer pricing, and intangibles.

[Austin:08] David Austin: Effects of Gasoline Prices on Driving Behaviour and Vehicle Markets; Congressional Budget Office, Congress of the United States, Jan.2008.

[Avril:11] Hillaire Avril: Africa, Emerging Trend Towards Establishing Offshore Tax Havens; Interpress Service (IPS), 17 Aug.2011.

[AviYonah:95] Reuven S. Avi-Yonah: “The Rise and Fall of Arm's Length: A Study in the Evolution of U.S. International Taxation”; Va. Tax Rev., Vol.15, 1995, p89.

[AviYonah:02] Reuven S. Avi-Yonah : For Haven's Sake: Reflections on Inversion Transactions; University of Michigan Law School, Tax Notes, Vol. 95 no. 12, June 17, 2002. ??AAAA

[AviYonahC:08] Reuven S. Avi-Yonah and Kimberly Clausing: “Reforming Corporate Taxation in a Global Economy: A Proposal to Adopt Formulary Apportionment”; in Paths to Prosperity [FurmanB:08], pp.319-344, 2008.

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[Babcock:68,94] Henry A. Babcock: Appraisal Principles and Procedures; American Society of Appraisers, 1968, fifth edition 1994.

[Baker:05] Raymond W. Baker: Capitalism’s Achilles heel, Dirty Money and How to Renew the Free Market System; Wiley, 2005.

[Baker:07] Leroy Baker: Halliburton Feels Democrat Wrath After Dubai Move; Tax-News.com, New York, 15 March 2007.

[Baranson:78] Jack Baranson: Technology and the Multinationals; Lexington Books, 1978. p. 64. Cited by [Caves:83]. Offshore movement of IP. Have chapter around p. 33; also see p.64.

[Barthold:11] Thomas A. Barthold: Response to Lloyd Doggett, containing revenue estimates for a new repatriation under IRC 965; Joint Committee on Taxation, Congress of the United States, 15 April 2011.

[BarlettS:00] Donald L. Barlett and James B. Steel: The Great American Tax Dodge, How Spiraling Fraud and Avoidance Are Killing Fairness, Destroying the Income Tax, and Costing You; Little, Brown, and Co., 2000. Have. Diatribe. Belize IRS staff inadequate p.21. No resources to chck EITC. p.27 . IRS cannot track extraterritorial transfers p.55. effect of Vereinsgesetz p67. Few Shjam tranascations get caught p.73 IRS unable to deal with Internet transactions p89.Domonizing the IRS p119, Constraints on IRS personnel p.123.audits of HNWI slow p.164.. sales tax p246.

[Barrett:12] Paul M. Barrett: “White Shoe Blues”; Bloomberg Businessweek; 23 April, 2012.

[Bartlett:12B] Bruce Bartlett: The Benefit and the Burden, Tax Reform, Why We Need It and What It Will Take; Simon and Schuster, 2012. Have. Excellent, covers all aspects of taxation and the imbalances created. But this three page proposal at the end has no numbers, exactly what he criticizes others about.

[Bartlett:12T] Bruce Bartlett: How to Avoid Reinventing the Wheel on Tax Reform; The New York Times, 24, 31 Jan.31, 2012. Avoid gimmicks, and focus on corporate taxation.

[Basili:90] Victor Basili: "Viewing Maintenance as Reuse-Oriented Software Development"; IEEE Software, Vol.7 No.1, Jan.1990, pp.19-25.

[Basse:11] Søren Hetland Basse: Science History and The Future; Royal Danish Library reg.1992, translated and updated 11 Feb.2011, . Developing countries

[Baum:10] Caroline Baum: The Good Old Bad Days; Bloomberg Businessweek; 6 Sep.2010, pp.4-5.

[Baumol:72] William J. Baumol: "On Taxation and the Control of Externalities", American Economic Review, Vol.62 no.3, Jun.1972, pp.307–322, JSTOR 1803378

[Basel:06] Basel Committee on Bank Supervision: International Convergence of Capital Measurement and Capital Standards; Bank for International Settlements, June 2006

http://en.wikipedia.org/wiki/American_Economic_Reviewhttp://en.wikipedia.org/wiki/American_Economic_Reviewhttp://en.wikipedia.org/wiki/JSTORhttp://www.jstor.org/stable/1803378


[Baxandall:12] Phineas Baxandall: Rogues Gallery of Major Corporate Legal Settlements; U.S. PIRG, 17 April 2012.

[Baz:09] Aureliano Gonzales Baz: Manufacturing in Mexico: The Mexican In-Bond (Maquila) Program; Banco Nacional de Comercio Exterior, 2009, .

[BEA:09] BEA: U.S. Direct Investment Abroad: Financial and Operating Data for U.S. Multinational Companies; Bureau of Economic Analysis, U.S. Department of Commerce,

[Bishop:08] Keith Paul Bishop: “Silver Standard”; Los Angeles Lawyer, Nov.2008, pp.32-42. California and Nevada corporate taxes. Nevada has 2.66% of out-of-state corporations, while Delaware has 91% of Calif. Corps, Local Ca. 0.19% only

[Bivens:11] Josh Bivens: Failure by Design: The Story behind America's Broken Economy; Cornell University Press, Economic Policy Institute, 2011. Bought, past statistics, only vague recommendations.

[Black:96] Fischer Black: Noise; Journal of Finance, July 1986 . Due to noise a range of two can be expected in the market [p.530-533].

[BlairM:06] David B. Blair and Dwight N. Mersereau: “Chief Counsel revamps case-specific advice procedures to match LMSB's new enforcement paradigms”; The Tax Executive, July-August, 2006.

[Blake:10] Rich Blake: Smaller Fish to Fry – IRS targets self-Employed; ABC News, 9April 2010. $345B. In 2006, the IRS conducted around 1.2 million examinations of individuals who earned less than $200,000; last year, there were around 1.3 million of those types of examinations. Still, roughly 90 percent of the 1.4 million IRS audits conducted in 2009 involved persons earning under $200,000. By comparison, the IRS conducted just 28,349 examinations of individuals who earned more than $1 million. The bulk of the agency's audit resources are allocated to its Small Business/Self Employment division. 150000B for self-employed schedule C filers.

[Blessing:09] Peter H. Blessing: testimony, Hearing on Banking Secrecy Practices and Wealthy American Taxpayers; The Subcommittee on Select Revenue Measures of the House. Committee on Ways and Means, 111th Cong. 2, 2009 http://waysandmeans.house.gov/media/pdf/111/pbless.pdf (, Partner, Shearman & Sterling “It never will be possible to eliminate criminal or fraudulent behavior in respect of financial accounts, even such behavior on a very large scale.”).

[Bloomberg:12] Bloomberg View: “The Silliness of Soak-the-Rich Schemes”; Bloomberg Businessweek, 23 Mar 2012. Based on HM Treasury study the 50% tax would only collect £2.4 instead of £7.8. Better get original study.

[Bloomquist:03] Kim M. Bloomquist: Tax Evasion, Income Inequality and Opportunity Costs of Compliance; 96th Annual Conference of the National Tax Association, 2003. Senior Economist, Internal Revenue Service Office of Research: widening income inequality contributes to the propensity to evade

[BlumenthalS:06] Marsha Blumenthal and Joel B. Slemrod: “The Compliance Cost of taxing Foreign Income its Magnitude, Determinants, and Policy Implications”; in [Slemrod:96] . a survey from corporate data, Does not consider tax havens.

[BodieKM:08] Zvi Bodie, Alex Kane, and Alan J Marcus: Investments, 8th edition; McGraw-Hill/Irwin, 2008. ( I have the 8th edition?, 9th edition 2010)


[BovenbergdM:94] A. Lans Bovenberg and Ruud A.. de Mooij: “Environmental Levies and Distortionary Taxation”; The American Economic Review, 1994, Vol.84 no.4 pp.1085-1089. Based on Baumal, . Considers affect on employment.

[BowlesS:10] Erskine Bowles and Alan Simpson (co-chairs): The Moment of Truth; plan by The National Commission on Fiscal Responsibility and Reform, The White House, 9 Dec.2010, 66pp. Deficit reduction. Earmarks 16B 2015. home mortgage about 4% of revenues for individuals.

[BradfordS:77] David F. Bradford and William E. Simon: Blueprints for Basic Tax Reform; Office of Tax Analysis, US Dep. of the Treasury, 17 Jan.1977. Income , consumption tax. In the model tax system corporate taxation is eliminated, Making C-corporations like S-corporations. Very careful description and discussion of many specific issues. True depreciation is advocated, but would be even harder for intangible assets.

[BrealeyMA:06] Richard A. Brealey, Stewart V. Meyers, and Franklin Allen: Principles of Corporate Finance, 8th edition; Mc GrawHill 2006. P/e ratio.

[Brennan:10] Thomas J. Brennan: “What Happens After a Holiday?: Long-Term Effects of the Repatriation Provision of the AJCA”; Northwestern Journal of Law and Social Policy, Spring 2010. Research on repatriation.

[BrewerBJ:12] Mike Brewer, James Browne and Paul Johnson: The 50p income tax rate: what is known and what will be known?; Chapter 9 in The IFS Green Budget, Institute for Fiscal studies, Feb.2012.

[Brill:12] Alex Brill: A Pro-Growth, Progressive, and Practical Proposal to Cut Business Tax Rates; Tax Policy Outlook, no.1, American Enterprise Institute, Jan 2012. Advocates gradually lowering Copr income tax to 25% - gets rid of domestic preference, . Disallow 10% of C-copps interest deductyibility. Make 50% depreciation permnant, gradually limit benefit for home mortage deduction; remove state and local tax deduction. Repeal AMT.

[Brittain:05] William Brittain-Catlin: Offshore – The Dark Side of the Global Economy; Farrar, Strauss and Giroux, 2005. Says: ‘In 2002 BP had more than US$500m in offshore capital invested in various financial instruments to speculate on the money markets, making it as much a bank as an oil producer.’ Focus on Cayman. In 2001 Cayman had $800B in deposits. Have.

[BronfenbrennerL:04] Kate Bronfenbrenner and Stephanie Luce: The Changing Nature of Corporate Global Restructuring: The Impact of Production Shifts on Jobs in the US, China, and Around the Globe; Cornell University, Oct.2004, . Annual loss 2001 204,000, 2004 406,000

[Brooks:95] Frederick Brooks: The Mythical Man-Month, Essays in Software Engineering; Addison-Wesley, 1975, reprinted 1995.

[Brooks:12] Sheena Brooks: France Blacklists SKN as Offshore Tax haven”; The St.Kitts Nevis Observer, 1 May 2012. See also http://www.panamalaw.org/nevis_llc_and_nevis_bank_account.html,

[BrooksKW:02] Bryant Brooks, Russell Kwiat, and Robert Weissler: Approaches to Valuing Cost Sharing Buy-Ins; IRS APA Program Training, Aug.20, 2002, . Foregone profits.

[BrownEa:12] Jim Brown et al.: “Report on the Mangement and Control Provision of the `International Tax Competiveness Act of 2011’”; New York State Bar Association, Tax Section, Report no. 1232, 31 January 2011. Treats certain CFCs as domestic corporations. Analysis of Lloyd Dogget, HR 5328.

[Browning: 07] Lynnley Browning: “Gimme Tax Shelter”; The New York Times, 4 Feb.2007, business section. Globalization. Netherlands, musicians.

[Browning:08] Lynnley Browning: “A One-time tax break saved 843 U.S. Corporations $265B”; The New York Times, 24 June 2008 .

[Browning:10] Lynnley Browning: “I.R.S. Shifts to Combat Tax Evasion”; The New York Times, 4 Aug.2010, business section. Centralization for LMSB information. Foreign Account Tax Compliance Act.

http://www.ifs.org.uk/budgets/gb2012/12chap9.pdfhttp://www.panamalaw.org/nevis_llc_and_nevis_bank_account.htmlhttp://www.irs.gov/pub/irs-apa/study_guide_exhibit_g.pdfhttp://www.irs.gov/pub/irs-apa/study_guide_exhibit_g.pdf

[Browning:11] Lynnley Browning: “Microsoft’s Use Of Lox-Tax Havens Drives Tax Bill to 7 Percent Of Profit”; Reuters / Huffington Post Business, 28 July 2011. Sales 14.4B, 30% increase in after in after-tax profit, 35% gain in earnings per share, 445M in taxes in the US 7% of 6.32 B in pre tax profit. With Dena Aubin, David Cay Johnston, Scott Malone and Bill Rigby, editing by Martin Howell). Puerto Rico: unusual credits.

[Buffett:11] Warren Buffett: “Stop Coddling the Super-Rich”; The New York Times, 14 Aug.2011.

[Burman:03] Leonard E. Burman: Is the Tax Expenditure Concept Still Relevant?; National Tax Journal, Sep.2003. The author is with The Urban, The Tax Policy Center. Georgetown University.

[Burman:11] Leonard E. Burman: Tax Reform Options: Marginal Rates on High-Income Taxpayers, Capital Gains, and Dividends; Statement before the Senate Committee on Fianace, 14 Sep.2011. Tax capital gains as income, use revenue to cut corporate tax. Nice graphs.

[Burman:99] Leonard E. Burman: The Labyrinth of Capital Gains Policy: a Guide for the Perplexed; The Bookins Institution, 1999.

[BurmanGT:08] Leonard E. Burman, Christopher Geissler, and Eric J. Toder: “How Big Are Total Individual Income Tax Expenditures, and Who Benefits from Them?”; American Economic Review, papers and proceedings, vol. 98 no. 2, May 2008, pp.79-83.

[BurnhamO:05] Paul Burnham and Larry Ozanne: Taxing Capital Income, Effective Rates and Approches to Reform; Congressional Budget Office, Congress of the United States, Oct.2005. Ignores IP, shows strong effect of borrowing versus equity financing. Proposes a.o non-deductabilty of interest and effect on effective tax rates, but not the amount lost.

[Bush:05] George W. Bush: President's Advisory Panel on Federal Tax Reform: "Simple, Fair, and Pro-Growth: Proposals to Fix America's Tax System"; 1 Nov. 2005, Doc 2005-22112, 2005 TNT 211-14. Comprehensive Business Income Tax (CBIT) proposal . To be applied to all businesses equally. Corporate intrest would not be deductinble, but taxed at 31.5% Eliminates taxation of dividendsd. Individula interst would not be taxed. [see Sullivan:11],[ Gideon:05]

[Byrne:12] Janet Byrne (ed.), The Occupy Handbook; Back bay Books, 2012. On Kindle

[ByrnesL:03] Nanette Byrnes and Louis Lavelle: The Corporate Tax Game; Business Week, 31 March 2003. Marriott. Limited IRS capability.

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[Cairncross:97] Frances Cairncross: The Death of Distance; Orion, 1997. Have.

[Camp:11] David Camp: Tax Reform Act of 2011; Ways and Means Discussion Draft, House of Representatives, 26 Oct.2011. Favors territorial taxation

[CampbellW:12] Matthew Campbell and Zijing Wu: “Why Europe’s Tech Firms Love New York”; Bloomberg Businessweek, 9 April 2012. Information on market to book ratio and IPO’s. 3.7 for MSCI index IT companies.

[Canale:09] David Canale et al.: Global Transfer Pricing Survey Findings – Tax Authority Insights; Ernst & Young, Thought Center Podcast, 2 Oct.2009. IRS adding 350 people. Services being finalized.

[Cantley:03] Beckett G. Cantley: “Corporate Inversions: Will the REPO Act Keep Corporations from Moving to Bermuda?”; Houston Business and Tax Law Journal, Vol. 3, 2003. Available at SSRN:


[CavenaughEa:04] John Cavenaugh, Jerry Mander, et al.: Alternatives to Economic Globalization, A better World Is Possible; Report of the International Forum On Globalization, 2nd Ed., Berrett-Koehler, 2004. Have, diatribe. $300B more outsourcing is possible for service jobs per McKinsey.

[Caves:07] Richard E. Caves: Multinational Enterprise and Economic Analysis, 3rd Ed ; Cambridge University Press, 2007. Have. Many multinationals exist because of a failure in the market for intangibles. Intra-form transactions are more profitable

[CavesCK:83] Richard E. Caves, Harold Crookell, and J. Peter Killing: "The Imperfect Market for Technology Licenses"; Oxford Bulletin of Economics and Statistics, 1983, pp.249-268. many multinationals exist because of a failure in the market for intangibles. Intra-firm transactions are more profitable

[CBO:05] CBO: Corporate Income Tax rates: International Comparison; Congressional Budget Office, Congress of the United States, Nov.2005. Shifting sources. Ignores investments in intangibles. Companies will invest in countries with lower taxrates (Chap.6, )

[CBO:08] CBO: Revenues, Outlays, Deficits, Surpluses and Debt Held by the Public, 1968 to 2007; Congressional Budget Office, Congress of the United States, Sep.2008. . Includes GDP

[CBO:11] CBO: The Budget and Economic Outlook: Fiscal Years 2011-2021; Congressional Budget Office, Congress of the United States, Jan.2011.

[CBO:12] CBO: Comparing the Compensation of Federal and Private-Sector Employees, Congress of the United States, Jan.2012. http://www.cbo.gov/ftpdocs/126xx/doc12696/01-30-FedPay.pdfl

[CCH:09] CCH Editorial Staff: Internal Revenue Code; 2 volumes, CCH Wolters Kluwer, Winter 2009. The material is also available on-line at the IRS web site and at [LLI:92]

[CCH:10] CCH Editorial Staff: Income Tax Regulations, including proposed regulations; 7 volumes, CCH Wolters Kluwer, Winter 2010. The material is also available on-line at the IRS web site and at [LLI:92]

[Censky:11] Annalyn Censky: “Boost spending on equipment, create more Jobs”; CNNMoney, 12 Sep.2011.

[Chaback:07] Patricia Chaback: Industry Directive #1 on Research and Experimentation (R&E) Credit Claims; IRS, 4 April 2007. IRS-RE07

[Chaback:08] Patricia Chaback : Tier 1, IRC 482 Cost-sharing Arrangements with Buy-in Payments; IRS IOE , April 2008. Directs use of cost-sharing per CIP, UIL, and taxregs 482-7. Best Method rule.

[ChadwickDlCLO:10] Alex Chadwick, Marcello Distaso, Guilaume Le Camus, Philippe Lion, and Rodrigo Ogea (eds): European Tax Transactions Guide; Baker & McKenzie, Tax Europe, 2010.

[Chamberlain:06] Andrew Chamberlain: Twenty Years Later: the Tax Reform Act of 1986; Tax Foundation, The Tax Policy Blog, 23 Oct 2006.

[Chambers:10] John Chambers: U.S. Jobs, innovation, Growth and Investment; Cisco Blog, 5 November 2010. 1 Trillion $ offshore. Lobbies for repatriation. Wih Safra Catz of Oracle. It costs the U.SD. taxpayer nothing. Earlier: : “most people forget that in a high-tech acquisition, you really are acquiring only people”i.

[ChapotonG:88] O. Donaldson Chapoton and Lawrence B. Gibbs: A Study of Intercompany Pricing; Claitor’s publishing; Discussion Draft, U.S. Treasury Department, 18 Oct.1988. Also referred to as the 1988 White Paper. page 121. Cost sharing was originally viewed as a way to allocate intangible income among related parties without requiring the complex determination of intercompany royalty rates. See also preamble to the 1995 cost sharing regulations. page10: thousands of different transactions. IRS p.14 Acces to pricing information p15: acess to foreigb accounts §982 for summons, p.21 Transfer of know how as services. p.54 Section 367. P:74 Safe Harbor p.109 Risk, History of Cost Sharing On PC Kindle as studyofIntercomp00unit.azw. Ordered. Foreifn source R&D

http://www.cbo.gov/budget/data/historical.pdfhttp://www.cbo.gov/ftpdocs/120xx/doc12039/01-26_fy2011outlook.pdfhttp://www.cbo.gov/ftpdocs/120xx/doc12039/01-26_fy2011outlook.pdfhttp://www.cbo.gov/ftpdocs/126xx/doc12696/01-30-FedPay.pdfl

[ChatfieldG:73] C. Chatfield and G.J. Goodhardt: “A Consumer Purchasing Model with Erlang Interpurchase times”; Journal of the American Statistical Association, Dec 1973, Vol. 68, pp.828-835.

[ChavezTW:98] Andrea Chávez, Catherine Tornabene, and Gio Wiederhold: "Software Component Licensing Issues: A Primer"; IEEE Software, Vol.15 No.5, Sept-Oct 1998, pp.47-52.

[Chittum:11] Ryan Chittum: “GE Flubs a Pushback Against The New York Times”; Columbia Journalism Review, 31 March 2011.

[ChoiSW:97] Song-Yong Choi, Dale O. Stahl, and Andrew Whinston: The Economics of Electronic Commerce; Macmillan, 1997.

[ChoiH:04] Eun Kwan Choi and James Hartigan (eds.): Handbook of International Trade, Vol.1; Basil Blackwell, 2004. Have?

[ChoiH:05] Eun Kwan Choi and James Hartigan (eds.): Handbook of International Trade, Vol.2; Basil Blackwell, 2005. Disconnect of law and economics.

[ChristensenCN:01] K. Christensen, R. Cline, and T. Neubig: “Total corporate taxation: `Hidden’”; National Tax Journal, Sep.2001, Vol.54 no.3, pp.495-506. above-the-line, non-income taxes

[ChristensenR:03] Clayton M. Christensen and Michael E. Raynor: The Innovator's Solution: Creating and Sustaining Successful Growth; Harvard Business school, 2003.

[Christians:09] Allison Christians: “Sovereignty, Taxation, and Social Contract”; Minnesota Journal of International Law, Vol. 18, August 2009, p.99. < http://ssrn.com/abstract=1259975>. Global vs national issues. US tax initiatives, OECD. Good citations. Sovereign countries have the right not to tax.

[Christians:10] Allison Christians: Taxation in a Time of Crisis: Policy Leadership from the OECD to the G20; 5 Nw. J. L. & Soc. Policy. 2010, p.19, . Belize, impossible to eliminate tax havens [Blessing:09]. [Rawls:71] notion of states versus the OECD.

[Churchill:26] Winston Churchill: “Double Income Tax”; Hansard of the House of Commons, Vol.194, 26 April 1926, p.1705. In principle tax only residents, but on all income. Double taxation only occurs when a `person’ has more than one legal residence. Then give a measure of relief.

[Churchill: 27] Winston Churchill: “Tax Avoidance”; Hansard of the House of Commons; Vol.205, 11 April 1927, pp.85-87. “it is clearly the business of the Government to watch for loopholes, and to propose remedial measures from time to time”;, “t is our duty to close these loopholes as far as possible before they are so widely resorted to as to injure the revenue”;

[CIP:05] Dept. of the Treasury: Coordinated Issue Paper; Large and Medium Size Businesses, IRS, LMSB-04—0907-9227, to be effective Sep.2007, first presented as Proposed Treasury Regulation §1.482-7(g)(4), 29 Aug.2005; Updated 30 jan 2012. . .

[Clark:10] Sue Clark: Letter of response to Martin Hearson, ActionAid UK; SABMiller plc, 11 Nov.2010, , retrieved 9 Dec.2010. Gv

[Clarke:99] William Clarke: How the City of London Works; Sweet and Maxwell, 1999.

[Clausing:03] Kimberly Clausing: “Tax Motivated Transfer Pricing and U.S. Intrafirm Trade Prices”; Journal of Public Economics, 2003, pp.2207 – 2223,

[Clausing:04] Kimberly Clausing: The American Jobs Creation Act of 2004, Creating Jobs for Accountants and Lawyers; Urban-Brookings Tax Policy Center, Dec.2004. 7.4% is corporate tax. Summarizesovisions. Gain $49B, cost 77B domestic production + 7B breaks `revenue raisers 82B+43B for repatriation

[Clausing:05] Kimberly Clausing: The role of U.S. Tax policy in Offshoring; Working paper, Dept.of Economics, Reed College, June 2005. Globalization. ??IIII

[Clausing:06] Kimberly Clausing: “International Tax Avoidance and U.S. International Trade”; National Tax Journal, June 2006. Multinational undertake 70% of US int. trade, and 41 % is intrafirm.

http://infolab.stanford.edu/CHAIMS/Doc/Papers/legal98/legalpaper.htmlhttp://infolab.stanford.edu/CHAIMS/Doc/Papers/legal98/legalpaper.htmlhttp://www.amazon.com/exec/obidos/search-handle-url/index=books&field-author-exact=Clayton%20M.%20Christensen&rank=-relevance%2C%2Bavailability%2C-daterank/102-9218966-3712937http://www.amazon.com/exec/obidos/search-handle-url/index=books&field-author-exact=Michael%20E.%20Raynor&rank=-relevance%2C%2Bavailability%2C-daterank/102-9218966-3712937http://ssrn.com/abstract=1259975http://www.actionaid.org.uk/doc_lib/sabmiller_right_of_reply_and_response1.pdf


[Clausing:09] Kimberly A. Clausing: Multinational Firm Tax Avoidance and Tax Policy; National Tax Journal, vol. 62 no.4, Dec 2009, pp.703-725. Here is the abstract: This paper considers the tax policy consequences of both real and financial types of international tax avoidance, focusing on U.S. multinational firms over the period 1982–2004. First, income shifting is examined by estimating the relationship between U.S. affiliate profit rates and foreign country tax rates. Second, the effects of taxes on multinational firms’ real operations across countries are considered. Estimates of both financial and real responsiveness to tax rate differences among countries are used to calculate how profits would differ from their current levels absent tax incentives, and thus how U.S. government revenues are affected. Finally, several policy alternatives are discussed, including formulary apportionment.

[ClevengerP:04] Novella Clevenger and Ken Pfannestiel: “Double Taxation of Dividends: Is the question resolved?; New Accountant, REN Publishing, 2004. Considers the 15% rate started by Bush in 2003 a reasonable compromise.

[Clinton:11] Hillary Clinton: Remarks preceding President Hu’s State visit to the U.S.; U.S. Department of State, 14 Jan.2011.

[Coglianese:11] Cary Coglianese: Federal Agency Use of Electronic Media in the Rulemaking process; Final Report to the Adminstrative Conference of the United States, Dec 2011; also “Enhancing Public Access to Online Rulemaking Information”; Michigan Journal of Environmental and Administrative Law, 2012.

[Coglianese:12] Cary Coglianese: Regulatory Breakdown: The Crisis of Confidence in U.S. Regulation; University of Pennsylvania Press, 2012. Have. Pigouvian taxation. 2Taxes vs. subsidies p.156

[CohanA:12] William D. Cohan and Jonathan Alter: “A fair and Balanced Plan for Eliminating the Corporate Income tax”; Bloomberg Businessweek, 25 June 2012.

[CohnC:11] Peter Cohn and Mathew Caminiti: The Multinational Advantage; Bloomberg Businessweek, 20 and 24 Jan 2011. Uses data from [MarkleS:09] North Carolina study.

[Collins:11D] Chuck Collins: Stop Corporate Tax Dodging: Talking Points and Background Information; Institute for Policy Studies, 23 Mar.2011. Picture of Ugland house

[Collins:11I] Lauren Collins: “House Perfect, is the IKEA concept comfy or creepy?”; The New Yorker magazine, 3 Oct.2011. Includes IKEA’s tax avoidance.

[CollinsS:99] Julie H. Collins and Douglas B. Shackelford: Corporate Domicile and Average Effective Tax Rates; in [Slemrod:99]. Canada, Japan, UK, US. Does not consider Tax havens

[Compustat:98] Compustat: Tools for Tranfer Pricing Analysis Developed by the APA program, 5 Mar.1998.

[Compustat:04] Compustat: Financial Results of Companies in SIC code 7372 for 1999 to 2002; obtained Nov.2004.

[Conard:12] Edward Conard: “Unintended Consequences: Why Everything You’ve Been Told About the Economy Is Wrong”; Portfolio, 2012. Bain Capital participant

[ConconiPR:07] Paola Conconi, Carlo Perroni, and Ryamond Riezamn: Is Partial Tax Harmonization Desirable?; European Center for Advanced Research in Economics and Statistics (ECARES), March 2007.

[Contractor:81] Farok J. Contractor: International Technology Licensing; Lexington Books, 1981.

[Contractor:01] Farok J. Contractor (ed):Valuation of Intangible Assets in Global Operations; Quorum, 2001. Collection of papers, have, Bargaining in IP negotiations [P.16], arm’s-length lag [p.120]. Bin Srinidhi: MNEs will devlop intangibles [p,173]. Profits under the 3 IRS methods [p177]. IP life [p220]. Ravi Sarathi: Ownership of software [p.225]. CISCO acquisitions [p.243]. Elisabeth King: Valuing the workforce [p.264]

[CookC:10] Nancy Cook and Eric Cook: System and method for analyzing tax avoidance; US patent 7,716, granted May 11, 2010. Focus on interstate transfers . Refers to IRC 482. Parameter-based. Chapter 5 formulas

http://academic.reed.edu/economics/clausing/http://ntj.tax.org/wwtax/ntjrec.nsf/009a9a91c225e83d852567ed006212d8/4228bae37c14ec788525769a006f4730?OpenDocumenthttp://ntj.tax.org/wwtax/ntjrec.nsf/009a9a91c225e83d852567ed006212d8/4228bae37c14ec788525769a006f4730?OpenDocument

[CordesEG:05] Joseph J. Cordes, Robert D. Ebel , and Jane G. Gravelle: Encyclopedia of Taxation and Tax Policy; Urban Institute Press, Oct.2005.

[Cornez:00] Arnold Cornez: The Offshore Money Book: How to Move Assets Offshore for Privacy, Protection, and Tax Advantage, 2nd Ed; Contemporary Books, 2000. Mentions IP, p.57,58.

[Cornford:04] Andrew Cornford: Enron and Internationally Agreed Principles for Corporate Governance and the Financial Sector; G-24 Discussion paper 30, UNCTAD, June 2004.

[CowenT:11] Tyler Cowen and Alex Tabarrok: Modern Principles, Macro Economics, 2nd Ed.; Worth Publishers, 2011. Easy reading, have. Low level expectations. New Philosophy? Nothing on intangibles or taxhavens.

[CoyD:11] Peter Coy and Jesse Drucker: “Apple, Google May Profit on a Tax Holiday”; Bloomberg Businessweek, 17 March 2011. Repatriation issues. Mentions formulary apportionment taxation.

[CremerG:00] Helmuth Cremer and Fahrouz Gahvari: “Tax Evasion, Fiscal Competition, and Economic Integration”; European Economic Review, Vol. 44, pp.1633-1657.

[Crichton :06] Michael Crichton: Canada adopts the Anticipated Profits Approach for Calculating a Reasonable Royalty Rate ; Canadian Intellectual Property Review, 24 CIFR, June 2006, pp.215-234. Author is with Gowlingss, LaFleur Henderson LLP, Ottawa, Canada.

[Cringely:95] Robert X. Cringeley: Steve Jobs: The Lost Interview; PBS and Channel 4 interview, 1995, 2011. “without data opolicy] business decisions are based folklore”

[Crowell:37} Chester Theodore Crowell: “Our Tax Jungle”; Harper’s Magazine, Nov 1937.

[CroninHKLP:11] Doug Cronin, Mike Heimert, Robert Kirschenbaum, Charles Larson, and Irving Plotkin: “ `Useful Life’ Determination in the Context of Intangibles Transfer Pricing Valuation Theoretical / Heuristic Framework for Analysis (i.e., Not Driven by Regulations)”; NABE Transfer Pricing Symposium, July 2011. —Boston Scientific, —Ceteris, —Miller & Chevalier, —IRS, —PWC

[Cusack:11] Bob Cusack: Gang of Six Collapses: Winners and Losers; The Hill, 22 May 2011.

[Cusumano:04] Michael A. Cusumano: The Business of Software; Free Press, 2004. Excellent review, with numbers and graphs. Favors synchronize and stabilize approach to software creation.

DDDDDDDD

[Dagan:00] Tsilly Dagan (Bar Ilan School of Law): The Tax Treaties Myth; NYU Journal of International Law and Politics , Vol. 32, Oct.2000, p.939-996.


[Damodaran:00] Aswath Damodaran: ”An Updated Amazon valuation”; working spreadsheet at

[DavisRKM:11] Benjamin Davis, Elizabeth Ridlington, Gary Kalman, and Jeffrey Musto: "Tax Shell Game: How much did Offshore Tax havens Cost you in 20102?"; U.S. Public Research Interest Group , 18 April 2011. http://www.uspirg.org/reports/usp/tax-shell-game-how-much-did-offshore-tax-havens-cost-you-2010>. Annual loss is $100B.

[delaVega:1668] Joseph Penso de la Vega: Confusión de Confusiones; 1668, reprint Wiley, 1996. The stock market, trading in shares of the second multinational, after the British East India Company.

[DelMonte:10] James Del Monte: IT Employer Information, Cost of Hiring/Turnover (CoH); JDA professional Services, 2010,


[DesaiFH:05E] Mihir A. Desai, C. Fritz Foley, and James R. Hines jr.: "Do Tax Havens Divert Economic Activity?“; Economics Letters, Vol.90, Elseviers 2006, p.219-24; also Ross School of Business Working paper Series no. 1024S, University of Michigan; SRN No. 704211, April 2005. Increases FDI in other offshore activities.

[DesaiFH:06] Mihir A. Desai, C. Fritz Foley, and James R. Hines jr.: "Taxation and Multinational Activity; New Evidence, New Interpretations“; Survey of Current Business, Vol.82 no. 6 Feb.2006, pp.16-22. Indirect foreign taxes do not receive tax credit.

[DesaiH:00] Mihir A. Desai and James R. Hines Jr.: "The Uneasy Marriage of Export Incentives and the Income tax"; Tax Policy and the Economy, Vol.15, MIT press; National Bureau of Economic Research, NBER working paper 8009, Nov.2000. IC-DISC and FSC, tax credit, Subpart F: passive income of CFCs is deemed distributed.

[DesaiH:04] Mihir A. Desai and James R. Hines jr.: “Old Rules and New Realities: Corporate Tax Policy in a Global Setting”; National Tax Journal, Vol.57 no.4, Dec.2004, pp937-960.

[DevereuxGK:03] Michael Devereux, Rachel Griffiths, and Alexander Klemm: Can international tax Competition explain Corporate Income Tax reforms?; .Compute effective tax rates (EMTR) as tax paid over earnings. Still based on reported taxable earnings.

[DevereuxH:03] Michael P. Devereux and R. Glenn Hubbard: "Taxing Multinationals"; International Tax and Public Finance, Springer, vol. 10 no.4, Aug.2003, pp.469-487. Formal model shows that worldwide taxation is not optimal even with credits and deductions if foreign taxes are high, but not if low, as in taxhaven. Deferral is limited and is at full rate.

[DevereuxK:09] Michael Devereux and Christian Keuschnigg: Distorting the Arms-length principle ; Oxford University Centre for Business Taxation, Working Paper 09/10 , July 2009. “arm’s length prices systematically differ from independent party prices”

[DevereuxL:11] Michael Devereux and Simon Lorentz: How would EU corporate tax reform affect US investment in Europe; National Bureau of Economic Research, NBER working paper 17576, Oct.2011. Many tables: various industries effective tax rates (EMTR). Rank China 22.48, Korea 19.8%Japan 36%, Canada 25.7% US 34.98, India 29.5Germany 27% UK.26.3%. Still based on reported taxable earnings.

[Dey:89] Richard Morris Dey: In the Way of Adventure: The Story of John Caldwell and Palm Island; Offshore Press, 1989, 35pp. Out of print.

[Dharan:02] Bata G. Dharan: Enron’s Accounting Issues – what we can learn to Prevent Future Enrons; Testimony prepared to US House Energy and Commerce Committee’s Hearings on Enron’s Accounting, Feb.2002.

[DharmapalaH:06] Dhammika Dharmapala and James R. Hines jr.: Which countries became Tax Havens? National Bureau of Economic Research, 2006, Cambridge; revised May 2009.

[DharmapalaFF:09] Dhammika Dharmapala, C. Fritz Foley, and Kirstin J. Forbes: `Watch what I do, Not what I say’: The unintended Consequences of the Homeland Investment Act; NBER working paper 15023, June 2009. HIA is an alternate for the AJCA. $300B repatriated the same amount paid out in dividends.

[DiamondZ:08] John W. Diamond and George R. Zodrow (eds): Fundamental Tax Reform: Issues, Choices and Implications; MIT Press, 2008. Foreword by James Baker III. Have.

[DickinsNW:05] Denise Dickins, Thomas G. Noland, and Kenneth M. Washer: “Primer on Partnership-Compensation Models”; The CPA Journal, Aug.2005.

[Dinh:10] Leuven Dingh: Transfer Pricing: IRS Disagrees With Tax Court's Findings, Legal Interpretations in 'Veritas' Ruling; BNA Daily Tax Report, 12 Nov.2010.

[Ditmer:11] Philip Dittmer: "U.S. Corporations Suffer High Effective Tax Rates by International Standards"; Tax Foundation Special Report No.195, Sep.2011.

[DLT:10] Deloitte : Uncertain Tax Positions and the IRS Transparency Initiative, No Holds barred; Deloite Development LLC, 10 May 2010.

http://www.people.hbs.edu/mdesai/beafinal.pdfhttp://www.people.hbs.edu/mdesai/beafinal.pdfhttp://ideas.repec.org/a/kap/itaxpf/v10y2003i4p469-87.htmlhttp://ideas.repec.org/s/kap/itaxpf.htmlhttp://ideas.repec.org/s/kap/itaxpf.html

[Doebele:04] Justin Doebele: "Flex Forward: Flextronics' Michael Marks says that outsourcing can only get much, much bigger”; Chief Executive, 1 July 2004.

[Doernberg:08] Richard L. Doernberg: International Taxation in a Nutshell, 8th edition; Thomson West Law, 2008, 612pp. On Kindle

[Dohmen:09] Joep Dohmen: “Multinationals betalen vrijwel geen belasting”; NRC Handelsblad, 21 Feb.2008, updated 25 Nov.2009,


Corporate R&D spending increased by $2 for every $1 tof tyax credit. Excludes work done outside the US governmental sponsored research, and social sciences research.

[DuPont:79] E.I. DuPont de Nemours & Co. v. United States, 608 F.2d 445 (Ct. Cl.1979). The basis for use of the Berry ratio.

[Dwoskin:12I] Elisabeth Dwoskin: “The Incrementalist”; Bloomberg Businessweek, 11 June 2012. Long article on Howard Marlow, president of the American League of Lobbyists. History of lobbying. 1029 members 2011 spending $3,32B

[Dye:08] Ronald A. Dye: Cost-sharing Agreements, a tax saving device for multi-nationals; Kellogg Insight, Northwestern Univ., April 2008.

[Elemendorf:11 ] Douglas W. Elmendorf: Reducing the Deficit: Spending and Revenue Options; Congressional Budget Office, Congress of the United States, Mar.2011, 182–83. .

[Ensinger:10] Dustin Ensinger: Multinational Corporations Creating Jobs...Overseas; Economy in Crisis, 4 Nov.2010. Based on [Sulivan:10] Tax Notes.

[Esenwein:06] Gregg A. Esenwein: Individual Capital Gains Income: Legislative History; Congressional Research Service (CRS), report for Congress, 19 May 2006

[EU:09] Savings Tax Directive, extended 2008. Focuses on taxing in the country of residence of the Beneficial owner.

[EU:03] Council of the European Union : Council Directive 2003/48/EC of 3 June 2003 on taxation of savings income in the form of interest payments;

[EU:08} Council of the Eurpean Union: Proposal for a Council Directive amending Directive 2003/48/EC on taxation of savings income in the form of interest payments; 23 Nov.2008.

FFFFFFFFF

[Farrell:12] Maureen Farrell: “Calpers: We’re getting even more activist”; CNNMoney, 2 May 2012.

[FarrellKS:05] Diana Farrell, Noshir Kaka, and Sascha Stürze: “Ensuring India's offshoring future”; McKinsey Quarterly, Sep.2005.

[FASB:85] Financial Accounting Standards Board: Accounting for the Costs of Computer Software to be Sold, Leased, or Otherwise Marketed - FAS 86; 1985. The capitalization of external use software development costs is required once functionality is demonstrated. Customer maintenance and support costs for computer software should be expensed when related revenue is recognized or when those costs are incurred, whichever occurs first,

[FASB:04] Financial Accounting Standards Board: Disclosures About Intangible Assets, Removal of Project on recognition of unrecognized intangibles; Financial Accounting Foundation, 21 May 2004.

[FASB:09] Financial Accounting Standards Board: Accounting Standards Codification, version 3; Financial Accounting Foundation, 2009. Not applicable as a basis for income tax determination. Formalizes intra-entity.

[FeenstraEa:10] Robert C. Feenstra et al.: Report on the Sate of Available Data for the Study of International Trade and Foreign Direct Investment; National Bureau of Economic Research, Working paper 16254, Aug.2010.

[FeenstraMRS:09] Robert C. Feenstra, Benjamin Mandel, Marshall B. Reinsdorf, and Matthew Slaughter: Effects of Trade Gains and Tariff Changes on the Measurement of U.S. Productivity Growth; NBER working paper No. 15592, Dec.2009, also working paper, Univ. of California, Davis , March 2008.

[Feinschreiber:01] Robert Feinschreiber: Transfer Pricing Handbook, 3rd edition; Transfer Pricing Consortium, John Wiley Publishers, April 2001.

[FeldsteinHH:95] Martin Feldstein, James R. Hines Jr. and R. Glenn Hubbard (eds.): Taxing multinational corporations; University of Chicago Press, 1995. Collection of analytical papers. Have

[FeldsteinS:78] Martin Feldstein and Joel Slemrod: "Inflation and the Excess Taxation of Capital Gains on Corporate Stock"; National Tax Journal Vol.31, 1978, pp.107–118;

[Felt:76] Mark Felt (Deep Throat): Discussion with Bob Woodward; All the President’s Men, Warner Brothers, 1976. True identity on revealed in 2006.

[Fernandez:10] Pablo Fernandez: Equity Premium: Historical, Expected, Required and Implied; IESE Business School, Spain, SSRN eLibrary,


[FishmanW:01] Raymond Fishman and ShangYu Wei: Tax rates and Tax Evasion: Evidence from `Missing Imports’ in China; National Bureau of Economic Research (NBER), working paper 8551, Oct.2001.

[Folbre:11] Nancy Folbre: Tax Havens and Treasure Hunts; The New York Times , 4 April 2011. Shows Corporate tax revenue/ GDP.

[Fornito:05] Roberto Fornito: Haftung imVerein; Müller-Eckstein Rechtsanwälte, Staad, Switzerland, 2005.

[Fors:97] Gunnar Fors: “Utilization of R&D Results in the Home and Foreign Plants of Multinationals”; The Journal of Industrial Economics, Vol.45 Issue 3, pages 341–358, September 1997. R&D is used by CFCs, but not the other way around.

[Fox:09] Justin Fox: The Myth of the Rational Market; Harper Business, 2009.

[Frank:11] Robert Frank: Are Taxes Causing the Rich to Renounce Their Citizenship?; The Wealth report, The Wall Street Journal, 13 June 2011. 499 left in 1q2011. No indication if they are rich.

[FreemanAB:09] Nick J. Freeman, George Abonyi, and Atipol Bhanich Sipapol: Globalization of Production and the Competitiveness of Small and Medium-sized Enterprises in Asia and the Pacific: Trends and Prospects; United Nations Economic and Social Commission for Asia and the Pacific, Studies in Trade and Investment No. 65 (ST/ESCAP/2540). 2009.

[Friedman:86] Milton Friedman: On the 1986 Tax Reform; Wall Street Journal: 7 July 1986. The end result is a tax system so complex that literally no one can master it in full detail. --From the citizens' point of view, the function of tax legislation is to decide who shall pay how much to finance government spending. But from Congress's point of view, tax legislation has an additional and very important function: It is a way to raise campaign funds. Why is it that hardly a year passes without a new tax bill? The reason is that so long as a tax bill is under consideration, with many billions of dollars at stake, lobbyists are actively pressing for the introduction or retention of special provisions to benefit their clients. And so long as lobbyists are active, thousand-dollar-a-plate dinners and similar devices will tap them for campaign funds. That is why members of Congress put such a high value on being assigned to the Ways and Means or Finance committees. And that is also why Congress has denied the citizenry the benefit of a tax system, changed only at long intervals, to which individuals and enterprises could adjust, rather than having to cope with continual and complex changes year after year.

[FriedmanW:03] Jack P. Friedman and Roman L. Weil (eds): Litigation Support Report Writing: Accounting, Finance, and Economic Issues; Wiley, 2003. Chapter 9: Robert L. Vigil: Intellectual Property /Software., pp.172-198. Have copy of section.

[Frisch:89] D. Frisch: “Method for Computing Royalty Under White Paper's BALRM”; Tax Notes Today, 89 TNT 107-30, 19 May 1989.

[Fukuyama:91] Francis Fukuyama: The End of History and the Last Man; Free press, 1991; reprint, 2006. At Johns Hopkins. Predicts integration and liberal democracy eventually globally, and no stable communism . Theories that can be tested within 20 years?. Concepts from Hegel and Nietzsche influenced new geopolitical policies from the US. In the light of those policies, his ideas are changing, in public. See also Huntington.

[Fukuyama:07] Francis Fukuyama: America at the Crossroads: Democracy, Power, and the Neoconservative Legacy; 2007. Push back from [Fukuyama:91].

[FurmanB:08] Jason Furman and Jason Bordoff: Path to Prosperity; Hamilton Project Ideas on Income Security, Education, and Taxes, Brookings Institution Press, 2008.

GGGGGGGGGG

[Gabriel:11] Trip Gabriel: “Gingrich Strikes Economic Themes in Hitting Romney”; New York Times, 27 Dec.2011. Supply side invokes Arthur Laffer curve , Jude Wanniski

[GaleH:11] William G. Gale and Benjamin H. Harris: Don’t Fall for Corporate Repatriation; Politico, Brookings Institution, 27 June 2011. 1.5Trillion offshore.

http://economix.blogs.nytimes.com/author/laura-dandrea-tyson/http://onlinelibrary.wiley.com/doi/10.1111/joie.1997.45.issue-3/issuetochttp://www.unescap.org/tid/publication/tipub2540.asphttp://www.unescap.org/tid/publication/tipub2540.asphttp://www.unescap.org/tid/publication/tipub2540.asphttp://www.unescap.org/tid/publication/tipub2540.asphttp://www.amazon.com/America-Crossroads-Democracy-Neoconservative-Legacy/dp/0300122535/ref=pd_bbs_sr_2/002-2720911-1117664?ie=UTF8&s=books&qid=1183163733&sr=1-2http://www.amazon.com/America-Crossroads-Democracy-Neoconservative-Legacy/dp/0300122535/ref=pd_bbs_sr_2/002-2720911-1117664?ie=UTF8&s=books&qid=1183163733&sr=1-2http://topics.nytimes.com/top/reference/timestopics/people/g/trip_gabriel/index.html?inline=nyt-perhttp://www.brookings.edu/experts/galew.aspx

[GAO:03] GAO: IRS and TIGTA Should Evaluate Their Processing of Employee Misconduct Under Section 1203; Government Accountability Office report GAO-03-394, February 14, 2003. Overdoing it leads to personnel problems.

[GAO:05] GAO: Tax Compliance: Better Compliance Data and Long-term Goals Would Support a More Strategic IRS Approach to Reducing the Tax Gap; Government Accountability Office, report GAO-05-753, 12 Jul. 2005.

[GAO:07] GAO: Tax Administration: Additional Time Needed to Complete Offshore Tax Evasion Examinations; Government Accountability Office report GAO-07-237, March 2007.

[GAO:08] GAO: Comparison of the Reported Tax Liabilities of Foreign- and U.S.-Controlled Corporations, 1998-2005; Government Accountability Office report GAO-08-957, July 2008.

[GAO:09] GAO, International Taxation: Large U.S. Corporations and Federal Contractors with Subsidiaries in Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions; U.S. Government Accountability Office report GAO-09-157, Dec.2008, 63pp. Of the 100 largest US corporations 83 have taxhaven subsidiaries.

[GAO:12] Internal Revenue Service, Interim Results of 2012 Tax Filing Season and Summary of the Fiscal Year 2013 Budget Request; US Government Accountability Office report GAO-12-566, 20 Mar.2012, 33pp. 2012 budget %305M less than 2011. Worse performance due to other finding peiorities. Requested increase $944.5M (8%) + 2.5B + 330M for modernization . Reduced performance goals. Dat in spreadsheet.

[GardnerR:98] William Gardner and Joseph Rosenbaum: Intellectual Property: Database Protection and Access to Information; Science, Vol. 281, Issue 5378, pp.786-787 , 7 Aug.1998.

[Garofalo:12] Pat Garofalo: CEOs of Tax Dodging Corporations Want to Cut Their Own Taxes Too; Nation of Change, 15 May 2012. In Obama’s plan for incomes over $250,000.

[Gates:98] Bill Gates: "Compete, don't delete"; Economist, 11 June 1998.

[GaukeEa:10] David Gauke et al.: Corporate Tax Reform: delivering a more comprehensive System; HM Revenue and Customs, 20 Oct. 2010. Planning By moving to full deductabilty of dividends for corporate profits, territorial taxation becomes closer. But taxhavens can stll be addressed.

[George:08] J. Russell George: Treasury Inspector General for Tax Administration Seminanual Report to Congress, Oct.2001 –March 2008; Inspector General for Tax Administration, TIGTA, 2008. Focus on intermnal audits. Acount Mnagment Servives (AMS). Tax gap of self-emplyment tax is $39B! Security. Tax law complexity. Excess IRA contributions. Idnty theft causing misreporting of income.

[George:11] J. Russell George: Management and Performance Challenges Facing the Internal Revenue Service for Fiscal 2012; Inspector General for Tax Administration, TIGTA, 14 Oct.2011. Tax l;aw changes, specically from the affordable Health care Act (HHS), includes tax credits. Earned Income Tax Credit EITC payment, Additional Child Tax Credit, Hope Scholarship cridt (dep.education) , Refundable adption credits, Electric vehicle credit (transporation) ,Hombuyer credit, Globalization Holdings have grown from $188B to in 1976 to 14.5T in 2007. Lack of information. Dealing with differing jurisdictions. Focus on-highrisk cases. FATCA, Significant foreign opposition to FATCA. Solution is to withhold 30% of apyments to forieign finacoal institution - but does not address IP. .. Effort needed to implement changes. Hunman capital “attempts by taxpayers and tax practitioners to evade compliance with the tax laws become more sophisticated.” Globalization US businesses from 368B (1996)to nearly 15T (2007) “The IRS is still challenged by a lack of information reporting on many cross-border transactions. In addition, the varying legal requirements imposed by different jurisdictions result in complex business structures that make it difficult to determine the full scope and effect of cross-border transactions.”, “The IRS expects that these efforts will improve international tax compliance by allowing it to focus on high-risk issues and cases with greater consistency and efficiency.”,


“Taxpayers with undisclosed foreign accounts and assets who do not submit a voluntary disclosure run the risk of detection by the IRS. If caught, these taxpayers face the imposition of substantial penalties, including the fraud and foreign information return penalties, as well as an increased risk of criminal prosecution. “, “According to the IRS Commissioner, “FATCA is an important development in U.S. efforts to combat offshore noncompliance. At the same time, the IRS recognizes that implementing FATCA is a major undertaking for financial institutions.”1[32] Based on the initial feedback from foreign financial institutions as well as foreign governments, the IRS will continue to face significant opposition from abroad in implementation of this Act.”

[GerdesS:09] Lindsey Gerdes and Louis Lavelle: “Best Places to Launch a Career”; Business Week, 14 Sep.2009.

[GerthMH:11] Jeff Gerth, Megan Murphy, and Vanessa Houlder: Corporations Couldn’t Wait to `Check the Box’ on Huge Tax Break; Probublica, Nation of Change, 27 Sept.2011.

[Gibbs:09] Robert Gibbs: Leveling the Playing Field: Curbing Tax Havens and Removing Tax Incentives For Shifting Jobs Overseas; The White House, 4 May 2009. US multinationals paid 2.3% tax in 2004.

[Gideon:05] Kenneth W. Gideon: The Comprehensive Business Income Tax; presentation slides, Skadden, Arps, Slade, Megher and Flom, 13 May 2005, . Distortion due to interst deduction and LLCs.

[Gigot:12] Paul Gigot?: Obama’s Dividend Assault; WSJ editorial, 22 Feb.2012. Diatribe.bad arithmetic at 20% actual the shareholder receives 80%, and at 39.6% pays a total 48.3% + 3.8healthcare =52%, much but not 64% now 32% Increase is x 1.63, much, but not 3 x as claimed . Interesting graph

[Gladstone:1898] William Gladstone: Notes from a Diary ; Sir Mountstuart Elphinstone Grant Duff, 1851-1901 (1898), p. 140: To be engaged in opposing wrong affords but a slender guarantee of being right.

[Gladwell:07] Malcom Gladwell: Open Secrets; The New Yorker Magazine, 8 Jan.2007; also in What the Dog Saw; Little Brown and Company, 2009.

[Gladwell:11] Malcom Gladwell: The Creation Myth; The New Yorker Magazine; 16 May 2011.

[Glass:03] Robert L. Glass: Facts and Fallacies of Software Engineering; Addison Wesley, 2003.

[Gleckman:02B] Howard Gleckman: Sealing off the Bermuda Triangle?; Business Week, 1 July 2002. Corporate Tax Shelters Includes example of Inversion by Tyco , using ADT, and transfer pricing. Chap 10

[Gleckman:02C] Howard Gleckman: Flatten the Corporate Tax Code; Business Week, 26 Feb.2002.

[Gleeson:94] William Gleeson: Anderson near to Pounds 1m per partner; The Independent, 12 June 1994. In five of the big six firms, the average profit per partner ranges from between pounds 340,000 and pounds 418,000

[GoldscheiderJM:02] Robert Goldscheider, John Jarosz, and Carla Mullhern: "Use of the Twenty-Five Percent Rule in Valuing Intellectual Property"; Les Novelles, LES, Dec.2002.

[Gooch:00] Lawrence Gooch: "In-Process R&D"; Chapter 9, p.176, Handbook of Advanced Business Valuation, McGraw-Hill, 2000. "... the cost approach is generally not a good measure of IPRG [in-process R&D] value”;

[Goodfriend:98] Marvin Goodfriend: Eurodollars; Chapter 5 in ; Federal reserve Bank of Richmond, VA, 1993 . 1988 estimate by Morgan 2,587B

[Goodman:67] George J.W. George (Adam Smith): The Money Game; Random House, 1967, republished 1976. On the stock market: “in the long-run the future earnings represent present value [although] in the short run the dominant factor is the elusive [...] temper of the crowd.

[Goodman:82] George J.W. George (Adam Smith): Paper Money; MacDonald & Co., 1982.

[Goolsbee:04] Austan Goolsbee, University of Chicago - Graduate School of Business; National Bureau of Economic Research (NBER): “The Impact of Corporate Income Tax: Evidence from State Organizational Form”; Journal of Public Economics, vol. 88 no. 112004, pp.2283-2299. In Retail establishments a 1% increase in corporate tax vs non-corporate tax reduced the share of corporate forms by 2.5% and 7% of sales.

[Gore:08] Al Gore: The Assault on Reason; Bloomsbury Publishing, 2008.

[GoreR:98] Al Gore and Robert E. Rubin: Reinventing Service at the IRS; GPO report 1998. MS01, Eliminate dollar goals.

[Gordon:62] Myron J. Gordon: The Investment, Financing and Valuation of the Corporation; Irwin, 1962; reprint Greenwood Press, 1982.

[GordonG:97] Joseph R. Gordon and Myron J. Gordon: "Finite Horizon Expected Growth Model"; Financial Analysts Journal, Vol.53 no.3, May June 1997, pp.52-61.

[GordonH:02] Roger H. Gordon and James R. Hines jr.: “International taxation”; in [AuerbachF:02] pp.1395-1995.

[Gowri:98] Aditi Gowri: “Speech and Spending: Corporate Political Speech Rights Under the First Amendments”; Journal of Business Ethics, Vol.17 no.16, Dec.1998, pp.1835-1860.

[GPO:12] US budget Summary Tables, Government Printing Office, 2009.

[Gravelle:09] Jane G. Gravelle: Tax Havens: International tax avoidance and evasion; Congressional research Service, 9 July 2009.

[GravelleS:06] Jane Gravelle and Kent A. Smetters: ‘‘Does the Open Economy Assumption Really Mean That Labor Bears the Burden of a Capital Income Tax?’’; Advances in Economic Analysis & Policy, Vol.6 no.1, 2006. Counteracts employee benefit assignments.

[Greeley:12] Brendan Greeley: ”Obama Spoils for an Election Year Tax Fight”; Bloomberg Businessweek, 27 Feb.2012. Pp.34-36. 28%rate. 2.7% of tax take on 2010. Keeps R&E, domestic manufacturing, & renewable energy.

[Gregory:12] Dolores W. Gregory: IRS Withdrawing 2007 Issue Paper on Cost Sharing Buy-Ins; BNA Daily Tax Report, Jan.20, 2012

[GriffithK:04] Rachel Griffith and Alexander Klemm: "What has been the tax competition experience of the past 20 years?“; Institute for Fiscal Studies, IFS working paper W04/05, 2004. [Downloadable!]

[GriffithS:09] Cara Griffith and Stephanie Stewart : Drop shipments and flash title: establishing sales tax nexus in complex commercial transactions; The Tax Adiser, Vol.40 No.9 American Institute of CPAs, 22 Sep.2009. On Amazon bookshelf. Defines, but applies it to State taxes. More description in [Waters:09].

[GrimesC:09] Seamus Grimes and Patrick Collins: “The Contribution of the Overseas ICT sector to expanding R&D investment in Ireland”; Irish Geography, Routledge, Vol.42 no.1, pp.45-67, 1 March 2009. Increasing FDI from manufacturing to R&D . Exploit local knowledge. Annual spending in US $200B; Ireland euro 3.2B/ 5years (see WW.data) Low corporate tax rate discourages R&D investment.

[Grimes:11] Seamus Grimes: Can China become an Innovation Hub?; East Asian Bureau of Economic

Research, , 2011.

[GrossmanH:94] Gene Grossman and Elhanana Helpman: "Endogenous Innovation in the Theory of Growth"; Journal of Economic Perspectives, Vol. 8, 1994, p.23-44.

[Grove:10] Andy Grove: “How to Make an American Job”; Bloomberg Businessweek, 5 July 2010, pp.48-53. 10x factor us vs. foreign employment. Scaling. Early investment. Breaking the chain of experience. Oiling the guillotine. Little specific advice.

[GrubertA:08] Harry Grubert and Rosanne Altshuler: “Corporate Taxes in the World Economy: Reforming the Taxation of Cross-Border Income”; in [DiamondZ:08], pp.319-354.

[Gu:01] Ferdinand A. Gu: Free cash flow, debt-monitoring and managers' LIFO/FIFO policy choice; Journal of Corporate Finance,Vol.7, Issue 4, Dec.2001, pp.475–492.

http://ideas.repec.org/p/ifs/ifsewp/04-05.htmlhttp://ideas.repec.org/p/ifs/ifsewp/04-05.htmlhttps://www.amazon.com/gp/ays/organize.html?asin=B002Q4899C&viewShared=0&targetCustomerId=A33VHGAPWY0VA4https://www.amazon.com/gp/ays/organize.html?asin=B002Q4899C&viewShared=0&targetCustomerId=A33VHGAPWY0VA4https://www.amazon.com/gp/ays/organize.html?asin=B002Q4899C&viewShared=0&targetCustomerId=A33VHGAPWY0VA4http://www.eastasiaforum.org/2011/07/22/can-china-become-an-innovation-hub/http://www.sciencedirect.com/science/journal/09291199http://www.sciencedirect.com/science/journal/09291199/7/4


[GuL:11] Feng Gu and Baruch Lev: “Overpriced Shares, Ill-Advised Acquisitions and Goodwill Impairment”; The Accounting Review, Nov.2011, Vol. 86 no. 6, pp.1995-2022.

[GuptaS:07] Amar Gupta and Satwik Seshasai: The 24-Hour Knowledge Factory, Using Internet technology to leverage spatial and temporal separations; ACM Transactions on Internet Technology (TOIT), Vol.7 no. 3, Aug.2007, article 14.

[GuptaWS:09] Amar Gupta, Gio Wiederhold , David Branson Smith, and Devin Sreecharana : Outsourcing from the Perspectives of International Protocols, Law, Intellectual Property, and Taxation; Arizona Legal Studies Discussion Paper 09-18 , University of Arizona, 7 Jan. 2009, .

[Guttman:03] George Guttman: “IRS Oversight Board’s Annual Report Too General to Be Useful”; Tax Notes, Aug. 11, 2003, p. 755.

HHHHHHHH

[HackerL12] Jacob S. Hacker and Nate Loewentheil: Prosperity Economics, Building an Economy for all; Yale University, 2012. Myths. Worker productivity vs compensation. Effective tax ratw low (p.59), Deferral . Low receipts. Stock option graph p.63

[HackerP:10] Jacob S. Hacker and Paul Pierson: Winner-Take-All Politics: How Washington Made the Rich Richer--and Turned Its Back on the Middle Class; Simon and Schuster, 2010. Entertaining diatribe, blames politics, uninformed electorate. Have.

[HallS:99] Joshua Hall and Jim Saxton: Tax Expenditures, A review and Analysis; Joint Economic Committee, United States Congress, Aug.1999. Stanley S. Surrey helped institute the "tax expenditure budget" in 1967 while he was Assistant Secretary for Tax Policy in the Treasury Department. In 1972, the Joint Committee on Taxation (JCT) began preparing an annual tax expenditure budget for the Committee on Ways and Means. In 1974, the Congressional Budget and Impoundment Control Act (PL 93-344) required that a list of tax expenditures be included in the annual budget.

[HallR:07] Robert E. Hall and Alvin Rabushka: The Flat Tax, silver anniversary edition; Hoover Institution Press Publication 423, Stanford, 2007. Ignores taxhavens. Proposes elimination of taxes dividend and capital gains, but includes interest earned by corporations. $127B not collected -18%.500,000people involved. Cost $335B. Intel example on page 66. Data on dividends and capital gains? Tax prepration time p.12; audir p.82,91

[Halperin:11] Daniel Halperin: "Is Income Tax Exemption for Charities a Subsidy?"; Tax law Review, Vol.64 no.3 , Spring 2011,p.283-312.

[Hampton:96] Mark Hampton: The offshore interface: tax havens in the global economy; Macmillan, 1996. Have. Includes Jersey study.

[Hand:35] Judge Learned Hand: Gregory v. Helvering; 69 F.2d 809, 810 (2d Cir.1934), aff'd, 293 U.S. 465, 55 S.Ct. 266, 79 L.Ed. 596, 1935; Yale Law Review, Vol.167, 1947.

[HandL:03] John Hand and Baruch Lev (eds.): Intangible Assets, Values, Measures. and Risks; Oxford University Press, 2003. .Network effect. In the year 2000 $61.4B was spent for prepackaged software, and $57B custom software. About $128B was spent by companies for internal software development and maintenance [Bureau of Economic Analysis] Chap. 12 provides data for routine and non-routine returns have.

[HanlonM:09] Michelle Hanlon and Edward L. Maydew: Book-Tax Conformity; National Tax Journal, Vol.62, p.127, 2009. University of Michigan and North Carolina , August 2006. Draft 2006

[Hansen:98] Reginald Hansen: Assessing and Tax Accounting Principles in the German Civil and Commercial Code and the Impact on Tax Compliance; European Journal of Law and Economics, Kluwer Academic Publishers, 1998, Vol.7 no.1, pp.15-47. Deterioration of the Massgeblichkeitsprinzip by the folk in the City of London.

[Harberger:62] Arnold V. Harberger: The Incidence of the Corporate Income Tax; The Journal of Political Economy, Vol.70 no.3, June 1962, pp.215-240. Equilibrium effects modeled as Corp/noncorp x

http://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=634202http://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=651858http://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=651858http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1324242##https://springerlink3.metapress.com/content/?Author=REGINALD+HANSENhttps://springerlink3.metapress.com/content/0929-1261/https://springerlink3.metapress.com/content/0929-1261/7/1/

labor/capital. Considers agriculture, real estate, and repair services non-corp vs all others. Old model, later improved. Shareholders bear the tax burden, not workers.

[Hardy:03] David R. Hardy: Assignment of Corporate Opportunities -- The Migration of Intangibles; Tax Notes, 145-33, July 28, 2003, p. 527. Author is with McDermott, Will & Emery. Globalization.

{Hargreaves11] Steve Hargreaves: “Big Oil’s 4$ billion tax break is in doubt”; CNNMoney, 29 April 2011.

[Harlan:1886] John Marshall Harlan: Santa Clara County v. Southern Pacific Railroad; US Supreme Court, Session 228, 394, 1886. Corporate person hood

[Harris:09] Harris: Corporate Tax Incidence and Its Implications for Progressivity”; Urban-Brookings Tax Policy Center, Nov.2009.

[Harrison:03] Bonnie Harrison: “Intangible Assets”; Chapter 10 in Weygandt, Kieso and Warfield: Fundamentals of Intermediate Accounting, Wiley 2003.

[Harvey:12] J. Richard Harvey: FATCA and Schedule UTP, Are these unilateral US actions doomed unless adopted by other countries?; Villanova Public Law and legal Theory Working paper series, No. 2012-2005, Mar.2012. FATCA requires multilateral coppration. UYTP disclousure Now it’s unilateral

[HassettB:07] Kevin A. Hassett and Alex Brill: “Revenue-Maximizing Corporate Income Taxes: The Laffer Curve in OECD Countries”; AEI Working Paper 137, Washington, DC, July 31, 2007, www.aei.org/paper/26577. NNN

[HassettM:10] Kevin A. Hassett and Aparna Mathur: Spatial Tax Competition and Domestic Wages; American Enterprise Institute for Policy Research (AEI), Working paper, 1 Dec 2010. Update of a 2006 paper Taxes and Wages. If capital stocks are depleted investment shifts to lower wage countries, depressing wages

[HassettM:11] Kevin A. Hassett and Aparna Mathur: Report Card on Effective Corporate Tax rates: United States Gets an F; Tax Policy Outlook 2011,No.1, American Enterprise Institute for Policy Research (AEI) no.1 Feb.2011. Statuary tax rates versus actual distribution.

[Hawkes:08] Alex Hawkes: Isle of Man urged to rebrand; Accountancy Age, 18 Jun 2008,


though tax bases simultaneously broadened, as a result of which average corporate tax collections actually rose from 2.1% of GDP in 1982 to 2.4% of GDP in 1999. The first is the experience of American multinational firms, whose average effective foreign tax rates fell from 43% in 1982 to 26% in 1999.

[Hines:05D] James R Hines, jr.: “Do Tax Havens Flourish?”; in J. Poterba (ed.), Tax Policy and the Economy, Vol.19, National Bureau of Economic Research and MIT Press.

[HinesS:09] James R Hines, jr. and Lawrence H. Summers: “How Globalization Affects Tax Design”; Tax Policy and the Economy, Vol.23. Ed. Jeffrey R. Brown and James M. Poterba. University of Chicago Press, 2009, 123-157. Small countries (not taxhavens) had to adapt already to deal with mobility of economic activity, and rely less on income taxes. During the period from 1950 to 2004, total world exports and imports grew by an average of 5.9 percent a year. From 1975 to 2004 the rate of growth of international trade relative to world output quickened for all goods to 2.3 percent a year, and for manufacturing to 3.0 percent a year. “given the looseness of the resulting legal restrictions, it is enterily possible for firms to adjust transfer prices in a tax-sensitve fashion without violating any laws” [p.7].

[Hines:10B] James R. Hines Jr.: "Reply to Becker and Feust"; National Tax Journal, Vol.63 no. 2. 2010, pp.278-280.

[Hines:10H] James R. Hines Jr.: "Treasure Islands"; Journal of Economic Perspectives, Vol.24 no. 4. Fall 2010, pp.103-126. Taxhavens may help overall economic growth, and have become more trustworthy – or their clients have become smarter in hiding what is going on. Mentions, but does not measure intangibles.

[HinesH:90] James R. Hines, jr. and R. Glenn Hubbard: “Coming home to America: Dividend repatriations by U.S. multinationals”; in [RazinS:90], 161-200. Financing differences in high tax (debt) and low tax countries (shares)

[HirscheyW:85] Mark Hirschey and Jerry J. Weygandt : Amortization Policy for Advertising and Research and Development Expenditures; Journal of Accounting Research, Vol. 23,No. 1, Spring, 1985, pp.326-335. 5. R&D amortization 10-20% advertising 10-20 for non-durable goods and 30-60% for durable goods, also later [HirscheyW:98] R&D has double the life of Marketing.

[Hirst:02] Clayton Hirst: “Silicon fen `needs £2bn’ to stop business exodus”; The Independent, 21 Sep.2002. .. urgent need for the UK Government to throw money at the road network.

[HirtlHK:09] Peter B. Hirtle, Emily Hudson, and Andrew T. Kenyon: Copyright and Cultural Institutions; Cornell University Library, 2009,

[HoggEa:08] Andrew Hogg et al.: Death and Taxes, the true toll of tax dodging; Christian Aid, London,UK, 2008. . 50% of world trade goes via taxhavens. Many references.

[Houlder:10B] Vanessa Houlder: “OECD Hails tax haven crackdown “; Financial Times, 19 Jan.2010.

[Houlder:10C] Vanessa Houlder: “Tax haven Drive will mean greater scrutiny”; Financial Times, 20 March 2010. Chinese G’vmnt uses information to stop taxhaven transfers.

[Houlder:11] Vanessa Houlder: “Secrecy Under Scrutiny: Pressure for transparency persists as havens yield billions for G20 treasuries”; Financial Times, 12 Jan.2011. Effect of amnesty after release of names of individuals from banks in Liechtenstein etc.

[HoulderMG:11] Vanessa Houlder ,Megan Murphy, and Jeff Gerth: Did Barclay’s Help U.S. Banks Get Undeserved Foreign Tax Credits?”; Financial Times, 25 Sept.2011.

[HousemanR:09] Susan N. Houseman and Kenneth R Ryder, jr (eds.): Measurement Issues Arising from the Growth in Globalization; Conference papers, National Academy of Public Administration, 6 Nov, 2009, 16 papers, 421 pp.

[Howard:95] Philip K. Howard: The Death of Common Sense; Random House, 1995. also see Steve Clemons, The Daily Show, 3 May 2011,


[IATI:12] IATI: The Israeli Success Story; Israel Advanced Techmnogy Industries, 2012, < http://www.iati.co.il/high-tech-in-israel/the-israeli-success-story>.

[Ibbotson:04] Ibbotson Associates: Stocks, Bonds, Bills, and Inflation; 2004 Yearbook, Wiley. The risk premium for 1926 through 1999 historic averages att of 8.1 percent ’ Cost of Capital 2000 Yearbook 34 states: “In all of the beta regressions, the total returns of the S&P 500 are used as the proxy for the market returns. The series used as a proxy for the risk-free asset is the yield on the 30-day T-bill”;

[Idris:03] Kamil Idris: Intellectual Property: A Power Tool for Economic Growth – Overview; World Intellectual Property Organization, 2nd Edition, June 2003.

[IMF:08] Thomas Dalsgaard @International Monetary Fund: Japan’s Corporate Income Tax – Overview and Challenges; IMF Working paper, WP/08/70, March 2008.

[Immelt:11] Jeffrey H. Immelt: Growth Starts Here, GE 2010 Annual Report; General Electric Corporation, 25 Feb.2011.

[ImmeltEa:11] Jeffrey Immelt, chair, The Jobs Council: Taking Action, Building Confidence”; Interim Report to the President, The President’s Council on Jobs and Competitiveness , 10 Oct.2011,

[IRS-ED:10] IRS: IRS Employee Data; retrieved Dec.2010, . 1500 attorneys in Office of the Chief counsel. 290 in LMSB in DC, PA NY IL TX CA

[IRS-EF:09] IRS: Fiscal Year 2008 Enforcement Results; 2009, . Amounts and FTE staffing

[IRS-F:06] IRS: Special Rules Regarding Certain Section 951 Pro Rata Share allocation; IRS Revenue Bulletin 2006-11, 13 March 2006.

[IRS-F:09] IRS: Transaction of Interest – Subpart F Income Partnership Blocker; IRS Notice 2009-7, 29 Jan.2009. Interaction of multiple CFs and a US partnership

[IRS-FR:93] IRS: The Final Regulations; A review of Comparability under the 1993 482 regulations; . Refers to Standard & Poor’s, Moody’s, several other databases.

{IRS-FT:11] IRS: Treasury and IRS Issue Guidance Outlining Phased Implementation of FATCA Beginning in 2013; IR-2011-76, 14 Jul.2011, . high risk accounts include private banking accounts with a balance that is equal to or greater than $500,000.

[IRS-MTC:06] IRS: United States Model Tax Convention of Nov.15, 2006; IRS, 15 Nov.2006. .

[IRS-OIC:11] IRS Chief Counsel: Disclosure and Privacy Law Reference Guide (§6103); pub. 4639, Sep. 2011, 331pp. History. Corporate records public to 1909, 1913 to 1977, when internal limits

[IRS-PP:10] IRS: Prompt Payment Act Interest rate; Treasury Direct, 2010,


[IRS-TP:94] IRS: Regulations on Transfer Pricing, Methods to Determine Taxable Income In Connection with a Transfer of Intangible Property; U.S. Internal Revenue Service: Title 26 Chap.I Subchap.A Part 1 §1.482-4, 8 Jul.1994; amended 4 Aug.2006, Federal Register, Vol.71 no.150, pp.44479-44519.

[IRS-TP:04] IRS: Studies into transfer pricing rules, Income Tax Treaties, and Corporate Expatriation, amendments to IRC § 482; US Congress, Subsec.806, Pub.L.108-357, 2004.

[IRS-TP:12] Regulations on Transfer Pricing, Methods to Determine Taxable Income In Connection with a Cost Sharing Arrangement; U.S. Internal Revenue Service: T.D. 9568, 19 Mar.2012.

[IRS-TS:06] IRS: Final report on Treatment of Services under Section 482--9T; Aug.2006, 189pp. CostPlusMethod ,

[IRS-WT:06] IRS: Withholding of Tax on Non-resident Aliens and Foreign Entities; IRS Publication No. 515, 2006, updated annually. Lists tax treaty countries in Table 3. See also

JJJJJJJJJ

[Jackson:10] James K. Jackson: Outsourcing and Insourcing Jobs in the U.S. Economy: Evidence based on Foreign Investment; Congressional Research Service, Report for Congress, Cornell University, 15 April 2010. Data specific for multinational corporations and their affiliates, outsourcing, productivity, employment over time, intrafirm trade, sales, R&D,

[JanebaS:03] Eckhard Janeba and Michael Smart: “Is Targeted Tax Competition Less Harmful than its Remedies?”; International Tax and Public Finance, Vol.10, 2003, pp.259-280. Uses immobile for tangible and mobile for capital and intangible assets.

[JCT:06] Joint Committee on Taxation: The Impact of International Tax Reform: Background and Selected Issues Relating to U.S. International Tax Rules and the Competitiveness of U.S Businesses; JCT report JCX-22-06, 21 June 2006. World-wide vs. Territorial.

[JCT:03] JCT: Report of the Joint Committee on Taxation Relating to the Internal Revenue Service as Required by the IRS Reform and Restructuring Act of 1998; Joint Committee on Taxation, 20 May 2003, 174pp., Modernization, recruitment, staff p.64, p160. Corporate Tax shelters p.5-6, Audit 5,7 32, 36, 85, unauthorized inspection of returns (§1203) p.9, 128-129, p.156 tax gap $280B and growing, Data on hrs/return corps and large corps p106 , Cycle days large corps 567 p.140. 80% need change p.141. appeals 250, tax court p151. Top salaries, with priors. p132. Tenure p.134.

[JCT:10] Joint Committee on Taxation: Present Law and Background Related to Possible Income Shifting and Transfer Pricing; JCT report (JCX-37-10, 20 July 2010. Section 936 Conversions-p.37.

[JCT:11] JCT: Tax Incentives for Research, Experimentation, and Innovation; Joint Committee on TaxationR&E §174. Compares other countries.forms get most (table 3) Complex, compliance cost.; and JCT: Background Information on TaxExpenditure Analysis and Historical Survey of Tax Expenditure Estimates; Joint Committee on Taxation JCX-15-11, 28 Feb.2011, 37pp. and JCX-45-11, 16 Sep.2011.

[JCT-12:12] JCT: Selected Issues Relating to Choice of Business Entity; Joint Committee on Taxation, 27 July 2012, JCX 66-12, 88pp. C-corps vs LLCs , pass-throughs . data 22.6 soleprops, 1.7M C-corps, 1.9m farms, 3.1 LLC, 4.1m S-corps.(since 1958) Gowing in all sizes, but more strable since 2003. In HMAT.xlx Corptax, Uniform pass-through. Large c-corp – large S corp by 2003

[JCT-18:12] JCT: Overview of the Federal Tax System as in Effect for 2012; Joint Committee on Taxation, 24 Feb.2012, JCX 66-18, 32pp. Good escription with data.

[JefferySO:88] David Jeffery, Brian Sturgeon, and Michael O’Brien: Tolley's Tax Investigations; Tolley Publishing, 1988.

[JensenM:76] Michael Jensen and William Meckling: “Theory of the Firm: Managerial Behavior, Agency Costs and Ownership Structure”; Journal of Financial Economics, 1976. Deinning:11: shareholders are the principals of the firm—i.e., they own it and benefit from its prosperity, while the executives are agents who are hired by the principals to work on their behalf.

http://www.amazon.com/s/ref=ntt_athr_dp_sr_1?_encoding=UTF8&sort=relevancerank&search-alias=books&field-author=Adrian%20Ogley

[JensenM:11] Mathew H. Jensen and Aparna Mathur: “Corporate Tax Burdens on Labor: Theory and Empirical Evidence”; Tax Notes, 6 June 2011. Employees’s wages are lowered because of the CIT per [Harris:09]. Critiques many prior analyses and observations. Mixed results, but employees seem to be affected.

[Johnson:05R] Calvin H. Johnson: Can the IRS be well liked?, Rossotti’s Many Unhappy Returns; Tax Notes, Tax Analysts, 2005. Remaining problems not addressed

[Johnson:05S] Calvin H. Johnson: Tales from the Skunk Works: The Basis-Shift or Defective Redemption Shelter; Tax Analysts, Special report, 2005. “Complexity has a tendency to intimidate and deter any outside review. “ Individual tax shelters promoted are FLIP — short for ‘‘Foreign Leveraged Investment Program’ using a Cayman corporation, ’; later OPIS — short for ‘‘Offshore Portfolio Investment Strategy’’ using a Cayman partnership and derivatives.

[Johnson:05V] Erinn R. Johnson: "A $13.5 billion merger between Symantec Corp. and VERITAS Software Corp"; Black Enterprise, 2005. 13.5M , later valued at 11B, actually paid 13.2

[Johnson:07] Calvin H. Johnson: “Replace the Corporate Tax with a Market Capitalization Tax”; Tax Notes, Vol. 117, 10 Dec. 2007, pp.1082.

[Johnston:03] David Cay Johnston: Perfectly Legal; Portofolio Publishers, 2003, Penguin 2005. IRS unaware of many tax fraud techniques p2. Audit as an option value p 168. Inversion p238. Jonathan Blattmachr p264. Congress unaware p294. Rossotti final report on audits p296. Audits down p298. Trust in ATA p300. Archer: pull it out by its roots p.301.

[Johnston:12] David Cay Johnston: Congress’ Potential Faulty Tax Logic; The National Memo, 3 March 2012. Lowering corporate tax should cause dividend rates to go up to counteract wage depression per [HasettM:10].

[JohnstonW:11] Louis Johnston and Samuel H. Williamson: What Was the U.S. GDP Then?; MeasuringWorth, 2011. URL:


[KaplanN:04] Robert S. Kaplan and David P. Norton; Strategy Maps: Converting Intangible Assets into Tangible Outcomes, Harvard Business School Press, 2004.

[Kaplow:99] Lois Kaplow :Tax complexity and enforcement; in [Slemrod:99]. p.389 – effect of weak enforcement. Does not consider IRS limits

[KarC:09] Dev Kar and Devon Cartwright‐Smith: Illicit Financial Flows from Developing Countries: 2002‐2006; Executive Report, 2009, Global Financial Integrity, Center for International policy, www.gfip.org.

[Keating:10] David Keating: A Taxing Trend: The Rise in Complexity, Forms, and Paperwork Burdens; National Taxpayers Union, NTU Policy Paper 127, April 15, 2010.

[KellerY:09] Wolfgang Keller and Stephen R. Yeaple: “Multinational Enterprises, International Trade, and Productivity Growth, Firm-level Evidence from the United States”; The Review of Economics and Statistics, MIT Press, vol. 91 no.4, pages 821-831. Data from the International Investment Division, U.S. Bureau of Economic Analysis (BEA). Published version of [KellerY:03].

[Kennedy:06] Justice Kennedy: Garcetti v. Ceballos, 547 U.S. 410; Supreme Court of the United States, 2006. First Amendment free speech protections for government employees. The plaintiff in the case was a district attorney who claimed that he had been passed up for a promotion for criticizing the legitimacy of a warrant. The Court ruled, in a 5-4 decision, that because his statements were made pursuant to his position as a public employee, rather than as a private citizen, his speech had no First Amendment protection.

[KesslerE:06] Wolfgang Kessler and Rolf Eicke: “Closer to Haven? New German Tax Planning Opportunities; Tax Notes International, Vol.42 no.6, 8 May 2006. Dutch Sandwiches are called and illustrated as Hilversum 1 & 2.

[KesslerE:10] Wolfgang Kessler and Rolf Eicke: “The New German GAAP – the Gap Between Commercial and Tax Accounting”; Tax Notes International, Vol.59 no.7, 16 Aug), 2010. For more than 100 years the principle of strict book-tax conformity (or the authoritative principle, or Maβgeblichkeitsprinzip) ("§ 5 exp. 1 P. 2 EStG “) was the most striking feature of German tax accounting. In fact, since the enactment of the German Commercial Code (Handelsgesetzbuch, or HGB) on Jan.1, 1900, this principle was a pillar that survived all storms of reforms until the last reform, the Accounting Modernization Act (Bilanzmodernisierungsgesetz) went into force on May 29, 2009.

[Khimm:11] Suzy Khimm: Bipartisanship lives! And it will likely cost taxpayers money; Ezra Klein’s blog, Washingon Post, 5 Oct 2011.

[King:10] Eizabeth King: Transfer Pricing and Corporate Taxation: Problems, Practical Implications and Proposed Solutions; Springer Verlag, 2010, 194pp. Have. Experience from private Practice. Cost-sharing loophole. Critique of CIP. eight case studies: 1. diamonds, 2. medical devices, 3. R&D Services, disks, WD? 4. Internet business model, 5 assets with embedded IP. 6 CDN services, Akamai, 7 global commodity trading, 8. Decentralized IP ownership.

[Kleinbard:07] Edward Kleinbard: Rehabilitating the Business Income Tax; June 2007.

[Kleinbard:12] Edward Kleinbard: “Stateless Income”; Florida Tax Rev., Vol.9, 2011, p. 699.

[Kopits:76] G. Kopits: “Intra-firm Royalties Crossing Frontiers and Transfer-Pricing Behavior”; The Economic Journal, Dec.1976, pp.791-803. Contractor 83: observes that the result of royalty setting is affected by tax minimization strategies.

[Kocieniewski:10] David Kocieniewski: “I.R.S. plans to uncover Companies’ Tax Strategies”; The New York Times, 24 Aug.2010.

[Kocieniewski:11B] David Kocieniewski: “U.S. Business Has High Tax rates, But Pays Less”; The New York Times, 2 May 2011.

[Kocieniewski:11G] David Kocieniewski: “G.E.’s Strategies Let It Avoid Taxes Altogether”; The New York Times, 24 March, 2011. Corp

References - Stanford Universityinfolab.stanford.edu/pub/gio/CS207/VICcitations.pdf · corporate income is the price of that protection. This price must be worth the benefits since,

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