Among other things, we’ll be discussing recent data concerning wealth inequality, and such proposals to address it as wealth taxation (a la the proposal by Senator Warren), expanded mark-to-market taxation (a la the proposal by Senator Wyden), Ed Kleinbard’s business enterprise income tax (BEIT) proposal, and raising income &/or estate & gift tax rates.
You can find the text of my brief Jotwell write-up here.
While in Singapore, I gave the first (I believe to be annual, but by a rotating list of people) Sat Pal Khattar Visiting Professor of Tax Law Lecture. The slides for this talk are available here. You also can find the most recent draft of the paper here.
The side trip to Bali was purely for vacation and relaxation. Ubud is getting crazily over-built and over-grown (hence, risking some of the charm I remember from a trip there 30 years ago), but the resort that we stayed at, about a half hour’s drive outside of the town proper, was exceptionally delightful.
More specifically, I’ll be among the members of a Tax Policy and Simplification Committee Panel at the ABA Tax Section meeting that has the current working title: “How Should the US Tax System Respond to the Growing Wealth Gap?: The Continuing Debate Over Wealth Taxes and Other Tax Proposals to Narrow the Gap Between Rich and Poor.”
Many thanks to Pamela Fuller for doing lots of hard work in getting this panel organized, although she won’t be appearing on it. My co-panelists will be Roger Royse, Linda Beale, and Richard Prisinzano.
We’re dividing up a set of related topics within the panel’s broader themes. For example, while others will take the lead in discussing such topics as recent empirical evidence regarding wealth inequality, Senator Warren’s wealth tax proposal, and Senator Wyden’s mark-to-market proposal for taxing capital gains upon accrual) I will do so with respect to (1) Edward Kleinbard’s dual BEIT proposal – an important income tax reform option that is often mysteriously under-appreciated, and (2) proposals to raise significantly the top rates in income and/or estate and gift taxes.
The event will be the first Sat Pal Khattar Professorial Lecture at the National University of Singapore (NUS) Law School. This is a venue that I know fairly well, as on three occasions I taught mini-courses there (in connection with the now-defunct NYU@NUS program).
The lecture is named for a generous leading Singaporean with a tax background, whom I look forward to meeting while there. I believe that Sat Pal Khattar Professorial Lectures on tax issues are meant to become a regular, perhaps even annual, event at the NUS Law School.
A poster for the event can be found here.
In terms of my professional activities, my forthcoming book, LITERATURE AND INEQUALITY: Nine Perspectives from the Napoleonic Era Through the First Gilded Age, remains on-track for April 2020 publication by the Anthem Press. Copy-editing has begun.
In mid-January, I’ll be traveling to Singapore to give a lecture at the NUS Faculty of Law as Sat Pal Khattar Visiting Professor of Tax Law. It will concern my work in progress, Digital Services Taxes and the Broader Shift From Determining the Source of Income to Taxing Location-Specific Rents. A final version of the piece will then appear in the Singapore Journal of Legal Studies. The lecture time is long enough that I’m preparing, and will post here, significantly longer and fuller slides than I have posted upon giving briefer talks concerning the piece.
My new article in process is well underway, albeit perhaps ready for seasonal hiatus. Its current working title is What Are Minimum Taxes, and Why Might One Favor or Disfavor Them? It will discuss, inter alia, what one might call the “Mortimer Adler” problem with using minimum taxes, how minimum taxes might be defined (and why minimum tax-ness might matter), and it will discuss in this regard institutional manifestations that include at least the following:
(1) the AMT,
(2) standalone versus minimum tax structure for taxing public companies’ reported financial statement income, with reference to the 1987-1989 AMT preference that was based on book income,
(3) the BEAT,
(4) GILTI (along with worldwide/foreign tax credit systems that are structurally similar, albeit typically not called minimum taxes if they tax foreign source income at the full domestic rate), and
(5) other global minimum taxes, such as the OECD’s Pillar Two proposal.
Leaving aside perhaps the biggest issue here, which pertains to taxing book income or not, the contrast between them raises the classic old issue of minimum taxes versus separate add-on taxes. I have begin writing about this issue more generally (including in my analysis the US experience with the individual and corporate AMTS, as well as global minimum taxes such as GILTI and the OECD Pillar Two Globe proposal. But it also goes way back for me. The first article I published after entering academe in 1987 was entitled something like “Perception, Reality, and Strategy: The New Alternative Minimum Tax.” I published it in Taxes Magazine so I could get it out fast, although in style and substance it was more like a Tax Law Review article.
I am not, however, writing the new article within a time frame that’s aimed at participating in the current Democratic campaign debate. I’m more interested in getting a general analysis out there that I think is presently lacking, although lots of experts have a decent grasp on some of the main points.
You can find the revised version here.
For now I’ve kept “Digital Services Taxes” as the first 3 words in the title, though this risks over-stating the extent to which the paper is actually about them as such. They remain a relevant piece of the paper’s analysis, and (at least so far) I couldn’t come up with a good title that didn’t start by referencing them.