Tips for Research assignment for Tax 9863

Darryl Steinberg, who teachers Tax 9863, Principles of Federal Income Taxation, is assigning his 85 graduate students to do research papers on one of the following three topics:






Homeland Reinvestment Act : Section 965
Limitation on Tax Deduction for Executive Compensation over $1M: 162(m)



Comparison of US Current Federal Income Tax System, Flat Tax Proposal and National Sales Tax.



I did a brief presentation of the tax related resources last night. These topics, he said, will be covered more in the secondary resources-journals, policy studies, law review articles, the WSJ, etc. I provided the students with an extensive handout. I also posted it on the shared Numan drive under the IS Division, Instruction, Instructional Materials and the folder Class Assignments.

Steinberg, who is the tax counsel for Lehman Brothers, told the students he thought CCH Tax Research Network was used by practioners more for the primary materials and RIA Checkpoint for the secondary materials and commentary and analysis.


To give you some heads up, the Homeland Reinvestment Act, section 965, was part of the American Jobs Creation Act of 2004, also known as Pub. Law. 108-357. This is a brief explanation of the IRS Code section 965:
As part of the American Jobs Creation Act of 2004 (Pub. L. 108-357), Congress provided U.S. multinational corporations with a temporary reduction in the U.S. tax imposed on certain dividends repatriated from their foreign subsidiaries. The stated reason for the tax benefit
was to stimulate the U.S. economy by triggering the repatriation of foreign earnings that would otherwise have remained abroad.



Relating to the executive compensation topic, in general:

For purposes of both the regular tax and alternative minimum tax, a publicly held corporation cannot deduct compensation (remuneration) to a covered employee to the extent the compensation exceeds $1 million per tax year (Reg. §1.162-27 There are some exceptions, explained in the code, cases and commentaries. One of the exceptions includes "golden parachutes." There is a division of opinion on whether this deduction should be increased or decreased, and policy questions in general about the deduction.

For the third, about the present U.S. federal tax system, and alternatives such as a national sales tax or a flat tax, there are many articles and studies on these alternatives. (These alternatives were proposed in a study prepared for President Bush that was done in 2005 by the President's Advisory Panel on Federal Tax Reform.

In the indexing of articles in ABI Inform Global, alternative names for a national sales tax are VAT (value added tax) and consumption tax.

The Congressional Research Reports, available on CCH Tax Research Network, have a number of studies on these topics. Other studies may be found in CIAO, NBER and SSRN. The tax treatises on RIA had information on these topics also. These taxes have been considered in other nations, and some countries have enacted them. The European Union has a VAT tax.
International tax treaties are available through the CCH database.

These topics all have many different stakeholders so there should be a wealth of research available.

Please let me know if you have any questions. The students just received the assignment and they will be working on the papers that are due at the end of the semester.