The first section of this report explains how these excludable dividend amounts (EDAs) work and how they affect the value of corporate tax preferences. The second section of the report details alternative approaches and their effects on corporate tax subsidies. The next section of the report explores the rationale for EDAs. The final section concludes with a review of general policy issues, including a discussion of the general types of corporate tax preferences currently allowed and a discussion of possible alternative approaches.
This report compares the provisions in H.R. 3768, the Katrina Emergency Tax Relief Act of 2005, as passed by the House with those in the amended version of the bill that was passed by the Senate.
This report discusses legislative initiatives regarding the alternative minimum tax (AMT) for individuals, which was originally enacted to ensure that all taxpayers, especially high-income taxpayers, paid at least a minimum amount of federal taxes.
Under provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA, P.L. 107-16), the estate tax and generation-skipping transfer tax are scheduled to be repealed effective January 1, 2010. But the estate tax repeal, and all other provisions of EGTRRA, are scheduled to sunset December 31, 2010. If the sunset provision is not repealed, or the law is not otherwise changed beforehand, in 2011 estate and gift tax law will return to what it would have been had EGTRRA never been enacted. The unified estate and gift taxes will be reinstated with an exclusion amount of $1 million. The maximum tax rate will revert to 55%.
The current income tax system is criticized for costly complexity and damage to economic efficiency. Reform suggestions have proliferated, including a national retail sales tax, several versions of a value-added tax (VAT), the much-discussed “Flat Tax” on consumption (the “Hall-Rabushka” tax), the “USA” proposal for a direct consumption tax, and revisions of the income tax. The President has indicated that major tax reform will be a priority item in his second term.
The Work Opportunity Tax Credit and Welfare-to-Work Tax Credit are temporary provisions of the Internal Revenue Code. Since their initiation in the mid-1990s, the Congress has allowed the credits to lapse four of the five times they were up for reauthorization. In each instance, they were reinstated retroactive to their expiration dates as part of large tax-related measures. The employment tax credits never have been addressed independently of broader legislation. This report describes the WOTC and WtW Tax Credit and outlines issues for members of Congress.
This report discusses the Economic Growth and Tax Relief Reconciliation Act of 2001, the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA, and the Working Family Tax Relief Act of 2004 (WFTRA). Since all of the tax reductions provisions of all three of these acts expire at some point in the future, Congress faces the issue of whether to extend and/or make the reductions permanent. Extending these tax reductions, however, is likely to significantly reduce federal revenues in the future.
P.L. 107-16, the Economic Growth and Tax Relief Reconciliation Act of 2001, repeals the federal estate tax for decedents that die in 2010. In addition, the act repeals the credit for state estate taxes for decedents dying after December 31, 2004, and replaces the credit with a deduction. In most states, the repeal of the tax and the significant increase in the federal exclusion will also repeal or diminish state estate, inheritance, and gift taxes.
It has been proposed to add individual accounts to Social Security in which investors could hold private securities. Calculations that project the earnings of individual accounts typically presume that they will earn a rate of return equal or close to the historical rate of return. But is there evidence that future rates of return will differ from history in predictable ways?
The 108th Congress is considering two major bills to provide tax incentives to increase the supply of, and reduce the demand for, fossil fuels and electricity: S.1149, the Energy Tax Incentives Act of 2003, approved by the Senate Finance Committee (SFC) on April 2, 2003 (superseding S. 597), and H.R. 6, introduced as H.R. 1531 and approved by the House on April 11, 2003, by a vote of 247-175.
Political organizations have the primary purpose of influencing federal, state, or local elections and conducting similar activities. Those that qualify under section 527 of the Internal Revenue Code are taxed only on a certain income. Under the Code, 527 organizations are subject to reporting requirements that involve registration, the periodic disclosure of contributions and expenditures, and the annual filing of tax returns. Section 527 organizations must also comply with applicable campaign finance laws. This report will briefly describe these organizations and the reporting requirements they face under the Code. The report will be updated as events warrant.
This report discusses the alternative minimum tax (AMT) with respect to the percentage of taxpayers who fall under the AMT as divided by state. The report also briefly addresses related legislation.
Several bills introduced in the 108th Congress included revenue-raising provisions, particularly those aimed at tax shelters that are generally used by corporations. In 2003, anti-sheltering provisions were included in several bills. This report is an overview of the revenue-raising provisions in the original reported versions of H.R. 2896 and S. 1637 and the final anti-sheltering bill as enacted.
This report discusses legislative initiatives regarding the alternative minimum tax (AMT) for individuals, which was originally enacted to ensure that all taxpayers, especially high-income taxpayers, paid at least a minimum amount of federal taxes.
This report discusses the Economic Growth and Tax Relief Reconciliation Act of 2001, the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA, and the Working Family Tax Relief Act of 2004 (WFTRA). Since all of the tax reductions provisions of all three of these acts expire at some point in the future, Congress faces the issue of whether to extend and/or make the reductions permanent. Extending these tax reductions, however, is likely to significantly reduce federal revenues in the future.
This report presents two approaches that have quite different implications for tax administration and Compliance. First, additional domestic investment would have both a direct tax benefit effect, and an indirect effect through increasing the ratio of domestic to world production. Secondly, if one considers the other provisions of H.R. 2896 and S. 1637, these provisions provide benefits (in some cases quite large benefits) to investment overseas that could more than offset any domestic incentive.
This report provides a brief overview of the alternative minimum tax (AMT) for individuals, discusses the issues associated with the current system, and describes current legislation to amend the AMT. The report will be updated as legislative action warrants.
This report discusses the idea of replacing our current income tax system with a flat-rate tax, including background and analysis and various Congressional proposals.
President George W. Bush has stated that tax reform will be one of his top priorities in the 109th Congress. Some form of a valueadded tax (VAT) has been frequently discussed as a replacement to the U.S. income tax system. In addition, some Members of Congress have expressed interest in the feasibility of using a value-added tax to finance health care reform.
The enacted provision of this legislation (H.R. 4520), following the passage of the Senate’s version (then S. 1637) and the House bill (H.R. 4520) followed the Senate version, which allowed a deduction and would cover unincorporated firms as well as corporations. However, the proposal contained the broader definition of manufacturing in the House bill which included oil and gas extraction, utilities, construction, and electricity. This report discusses the provisions in these two versions of the subsidy as well as some of the issues surrounding alternative methods of providing a manufacturing subsidy.
The U.S. tax code’s Foreign Sales Corporation (FSC) provisions provided a tax benefit for U.S. exporters. However, the European Union (EU) in 1997 charged that the provision was an export subsidy and thus contravened the World Trade Organization (WTO) agreements. A WTO ruling upheld the EU complaint, and to avoid WTO sanctioned retaliatory tariffs, U.S. legislation in November 2000 replaced FSC with the “extraterritorial income” (ETI) provisions, consisting of a redesigned export tax benefit of the same magnitude as FSC. The EU maintained that the new provisions are also not WTO-compliant and asked the WTO to rule on the matter.
The U.S. tax code’s Foreign Sales Corporation (FSC) provisions provided a tax benefit for U.S. exporters. However, the European Union (EU) in 1997 charged that the provision was an export subsidy and thus contravened the World Trade Organization (WTO) agreements. A WTO ruling upheld the EU complaint, and to avoid WTO sanctioned retaliatory tariffs, U.S. legislation in November 2000 replaced FSC with the “extraterritorial income” (ETI) provisions, consisting of a redesigned export tax benefit of the same magnitude as FSC. The EU maintained that the new provisions are also not WTO-compliant and asked the WTO to rule on the matter.
The U.S. tax code’s Foreign Sales Corporation (FSC) provisions provided a tax benefit for U.S. exporters. However, the European Union (EU) in 1997 charged that the provision was an export subsidy and thus contravened the World Trade Organization (WTO) agreements. A WTO ruling upheld the EU complaint, and to avoid WTO sanctioned retaliatory tariffs, U.S. legislation in November 2000 replaced FSC with the “extraterritorial income” (ETI) provisions, consisting of a redesigned export tax benefit of the same magnitude as FSC. The EU maintained that the new provisions are also not WTO-compliant and asked the WTO to rule on the matter.
The U.S. tax code’s Foreign Sales Corporation (FSC) provisions provided a tax benefit for U.S. exporters. However, the European Union (EU) in 1997 charged that the provision was an export subsidy and thus contravened the World Trade Organization (WTO) agreements. A WTO ruling upheld the EU complaint, and to avoid WTO sanctioned retaliatory tariffs, U.S. legislation in November 2000 replaced FSC with the “extraterritorial income” (ETI) provisions, consisting of a redesigned export tax benefit of the same magnitude as FSC. The EU maintained that the new provisions are also not WTO-compliant and asked the WTO to rule on the matter.
The U.S. tax code’s Foreign Sales Corporation (FSC) provisions provided a tax benefit for U.S. exporters. However, the European Union (EU) in 1997 charged that the provision was an export subsidy and thus contravened the World Trade Organization (WTO) agreements. A WTO ruling upheld the EU complaint, and to avoid WTO sanctioned retaliatory tariffs, U.S. legislation in November 2000 replaced FSC with the “extraterritorial income” (ETI) provisions, consisting of a redesigned export tax benefit of the same magnitude as FSC. The EU maintained that the new provisions are also not WTO-compliant and asked the WTO to rule on the matter.
The U.S. tax code’s Foreign Sales Corporation (FSC) provisions provided a tax benefit for U.S. exporters. However, the European Union (EU) in 1997 charged that the provision was an export subsidy and thus contravened the World Trade Organization (WTO) agreements. A WTO ruling upheld the EU complaint, and to avoid WTO sanctioned retaliatory tariffs, U.S. legislation in November 2000 replaced FSC with the “extraterritorial income” (ETI) provisions, consisting of a redesigned export tax benefit of the same magnitude as FSC. The EU maintained that the new provisions are also not WTO-compliant and asked the WTO to rule on the matter.
The U.S. tax code’s Foreign Sales Corporation (FSC) provisions provided a tax benefit for U.S. exporters. However, the European Union (EU) in 1997 charged that the provision was an export subsidy and thus contravened the World Trade Organization (WTO) agreements. A WTO ruling upheld the EU complaint, and to avoid WTO sanctioned retaliatory tariffs, U.S. legislation in November 2000 replaced FSC with the “extraterritorial income” (ETI) provisions, consisting of a redesigned export tax benefit of the same magnitude as FSC. The EU maintained that the new provisions are also not WTO-compliant and asked the WTO to rule on the matter.
The Foreign Sales Corporation (FSC) provisions of the U.S. tax code permit U.S. firms to exempt between 15% and 30% of export income from taxation. FSC was enacted in 1984 to replace another tax benefit for exporting - the Domestic International Sales Corporation (DISC) provisions. U.S. trading partners had charged that DISC was an export subsidy, and so violated the General Agreement on Tariffs and Trade (GATT). In 1998 the European Union (EU) complained to the World Trade Organization (WTO, GATT's successor) that FSC itself is an export subsidy and violates the agreements on which the WTO is based. A WTO panel subsequently supported the EU. Under WTO procedures
This report provides a brief overview of the U.S. international tax system, the mechanics of FSC’s partial tax exemption, and how FSC fits into the overall U.S. tax structure.
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