The Income Tax and the Uniform: United States Tax Court Rules That Nurses May Deduct the Cost of Uniforms for Federal Income Tax Purposes

1943 ◽  
Vol 43 (9) ◽  
pp. 823
Author(s):  
D. B. Chase
Keyword(s):  
United States ◽  
Income Tax ◽  
Federal Income Tax ◽  
Tax Court ◽  
The Cost

Tax Expenditures and the Tax Reform Act of 1969 in the United States

2022 ◽  
pp. 1-26
Author(s):  
Seiichiro Mozumi
Keyword(s):  
United States ◽  
Income Tax ◽  
Public Perception ◽  
Tax Reform ◽  
The United States ◽  
Tax Revenue ◽  
Tax System ◽  
Federal Income Tax ◽  
Federal Taxation ◽  
The Government

Abstract In the United States, tax favoritism—an approach that has weakened the extractive capacity of the federal government by providing tax loopholes and preferences for taxpayers—has remained since the 1930s. It has consumed the amount of tax revenue the government can spend and therefore weakened the possibility of the redistribution of fiscal resources. It has also made the federal tax system complicated and inequitable, resulting in undermining taxpayer consent. Therefore, since the 1930s, a tax reform to create a simple, fair, and equitable federal income tax system with the capacity to raise revenue has been long overdue. Many scholars have evaluated the Tax Reform Act of 1969 (TRA69), which Richard M. Nixon signed into law on December 30, 1969, as one of the most successful steps toward accomplishing this goal. This article demonstrates that TRA69 left tax favoritism in the United States. Furthermore, it points out that TRA69 turned taxpayers against the idea of federal taxation, a shift in public perception that greatly impacted tax reform in the years to follow.

Is There a December Effect? Strategic Prepayments of Deductible State Income Tax

2010 ◽  
Vol 32 (2) ◽  
pp. 53-71
Author(s):  
John Shon ◽  
Stanley Veliotis
Keyword(s):  
Income Tax ◽  
Time Value Of Money ◽  
State Income Tax ◽  
Federal Income Tax ◽  
State Income ◽  
Tax Savings ◽  
Tax Payments ◽  
One Year ◽  
The Cost ◽  
Value Of Money

ABSTRACT: Individuals’ state income tax payments are deductible in the year paid for federal income tax purposes. This study investigates whether, and to what extent, individuals implement federal tax planning by prepaying state estimated income taxes before year-end, even though those payments are not due until January 15. Based on a study of 34 states’ aggregate data on estimated income tax receipts from individuals, we find strong evidence of this effect. We also find that this effect is increasing with the cost of state income tax payments. The results suggest that individual taxpayers take steps to reduce taxes by shifting deductions from one year to an earlier year and/or exploit the time value of money provided by accelerating federal tax savings by one year.

scholarly journals Interest Relief on Income Tax Debts: Canada Versus the United States

2021 ◽  
Vol 68 (4) ◽  
pp. 931-986
Author(s):  
Michael H. Lubetsky
Keyword(s):  
United States ◽  
Voluntary Disclosure ◽  
Income Tax ◽  
The United States ◽  
The Public ◽  
The Us ◽  
Fair Compensation ◽  
Willingness To Use ◽  
Tax Court ◽  
The Comparative Study

Subsection 220(3.1) of the Income Tax Act authorizes the minister of national revenue to waive or cancel interest on income tax debts. This power is typically exercised in four circumstances: where interest has accumulated owing to circumstances beyond a taxpayer's control; where the interest has accumulated owing to error or delay by the Canada Revenue Agency; where the accumulated interest causes hardship; or in the context of a voluntary disclosure. South of the border, section 6404 of the Internal Revenue Code authorizes the secretary of the Treasury to "abate" interest on tax debts. As a practical matter, discretionary interest relief under section 6404 is available only in very limited circumstances. The restrictive approach to discretionary interest relief is, however, offset by a greater array of interest-relieving provisions, as well as by the power of the secretary to "compromise" tax liabilities on various grounds, some of which overlap with grounds for interest relief recognized in Canada. This article compares the Canadian and US interest relief regimes, with a view to identifying aspects of the US regime that may merit further consideration in Canada. The differences in the US approach that are of particular interest include • a wider, and arguably more coherent, range of relieving provisions applicable to interest, particularly with regard to interest netting and carrybacks; • the jurisdiction of the United States Tax Court to review refusals to abate interest and/or to accept an offer in compromise; • dealing with situations of hardship and extraordinary circumstances under the aegis of the offer-in-compromise regime, which allows for consideration of the underlying tax liability in addition to the interest, and which also allows for relief to be made conditional on the taxpayer's future compliance with filing and payment obligations; • in certain older cases, a willingness to use interest relief to settle longstanding and complex tax disputes; and • the absence of statutory time limits on the power of the secretary to abate or compromise interest. The comparative study also reveals how Canada and the United States place different weight on policy rationales that underlie interest relief. Canada focuses mainly on ensuring that the consequences of non-compliance for individual taxpayers are fair and equitable. The United States, on the other hand, focuses more on rehabilitating non-compliant taxpayers in the long term, as well as ensuring that interest reflects fair compensation for such taxpayers' use of the public treasury's money—both of which could be given greater attention on this side of the border.

Federal Estate and Gift Taxes: Are They Worth the Cost?

1996 ◽  
Vol 9 (3) ◽  
pp. 295-302 ◽  
Author(s):  
Pat Soldano
Keyword(s):  
Income Tax ◽  
Capital Accumulation ◽  
Job Creation ◽  
Business Growth ◽  
Estate Tax ◽  
Estate Taxes ◽  
Federal Income Tax ◽  
Family Harmony ◽  
The Cost ◽  
The Impact

Everyone is aware of the federal income tax. What many do not realize is that federal estate tax may have a bigger impact than the income tax. While the income tax decreases take-home pay, the estate tax threatens job creation, business growth, and family harmony. This article examines the impact of the federal estate taxes and reviews several studies which indicate that the estate tax has a deleterious impact on capital accumulation, business growth, job creation, and federal tax revenues.

The Evolving Distribution of Giving in the United States

2020 ◽  
pp. 089976402097769
Author(s):  
Nicolas J. Duquette
Keyword(s):  
United States ◽  
Income Tax ◽  
The United States ◽  
Donor Concentration ◽  
Cross Sectional ◽  
Tax Returns ◽  
Federal Income Tax

I compute the share of U.S. household giving accounted for by the American tax units donating the largest amounts over the 1960–2012 period from repeated cross-sectional samples of federal income tax returns. The share of donations accounted for by a minority of top donors rose sharply over this period. Donor concentration has risen both because the largest gifts have grown larger and because more households give little or nothing in any given year.

scholarly journals Implications Of The Selection Of A Method To Allocate State Income Taxes In Order To Determine Net Foreign-Source Income

2010 ◽  
Vol 9 (4) ◽  
Author(s):  
Robert M. Kozub
Keyword(s):  
United States ◽  
Income Tax ◽  
The United States ◽  
Income Taxes ◽  
Income Sources ◽  
State Income ◽  
Gross Income ◽  
State And Local ◽  
Tax Court ◽  
Relationship Of

Internal Revenue Code Sections 861-864 determine the source of income and Sections 861(a) and 862(a) specifically allocate certain items of gross income to sources within or without the United States.  Sections 861(b) and 862(b) state generally how to determine taxable income for a taxpayer with income sources within or without the United States after such source has been determined. Regulation § 1.861-8 provides more information on allocating state and local taxes to U.S. - and foreign-source income.  Regulation § 1.861-8 is based on the factual relationship of deductions to gross income test.  This Regulation provides a concise rule requiring that the deduction for state, local, and foreign income, war profits, and excess profits taxes under Section 164 are definitely related and allocable to the gross income with respect to which such taxes are imposed. Under Regulation § 1.861(e)(6) if foreign-source of a corporation related by ownership to a corporate taxpayer is attributed to the activities conducted by the taxpayer in a state and is subject to state income tax, as in a state unitary income tax, the state tax deduction is allocable to the foreign-source income of the related corporation for purposes of the foreign tax credit used § 904.  This paper first considers the most common methods for allocating state income taxes, the presumptive, analytic, and state-by-state methods.  In the Chevron case, the Tax Court was asked to consider whether any of the following methods comply with the regulations; these methods are the gross income, factor operations, statutory notice, the pro rata, and the example methods.  This paper will also consider the requirements and validity of related regulations.

The Kennedy–Johnson Tax Cut of 1964, the Defeat of Keynes, and Comprehensive Tax Reform in the United States

2017 ◽  
Vol 30 (1) ◽  
pp. 25-61
Author(s):  
Seiichiro Mozumi
Keyword(s):  
United States ◽  
Tax Policy ◽  
Income Tax ◽  
Tax Reform ◽  
The United States ◽  
Legislative Process ◽  
Tax System ◽  
House Committee ◽  
Federal Income Tax ◽  
Treasury Department

Abstract:In 1964, President Lyndon B. Johnson, the successor of John F. Kennedy, signed into law the largest tax cut in U.S. history until 1981, the so-called Kennedy–Johnson tax cut. Many scholars have evaluated it as representative Keynesian tax policy; this article focuses on the effort of the Treasury Department, tax experts such as Stanley S. Surrey and Wilbur D. Mills, the chairman of House Committee on Ways and Means, to reform the federal income tax system comprehensively—making it simpler, fairer, and more equitable—and their defeat by the 1964 tax cut. Through the policymaking and legislative process, the Kennedy administration’s Council Economic Advisers defeated the Treasury and Surrey by domesticating Keynes’s ideas on tax policy. Until the 1964 passage of the tax cut, Mills, with his inconsistent action, abandoned the accomplishment of their ideal tax reform.

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