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Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Die Unternehmensbesteuerung (Ubg) is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Capital gains tax burden from rebalancing is a major concern for managing factor portfolios in taxable accounts. This article conducts 98 simulated backtests over a 10-year investment horizon spanning from 1964 to 2021 to investigate this issue under heuristic constraint-based algorithm. The authors find that value, quality, and safety buy-and-hold (BH) portfolios were able to generate significant pretax and after-tax alphas without any rebalancing. Based on this observation, they construct a composite factor using these three factors. The composite factor portfolios consistently outperformed the benchmark in more than 80% of the simulated backtests. Their performance can be further improved by allowing trades so long as they do not realize any net capital gains, such as tax-loss harvesting and selling factor losers only when they do not carry any capital gains. The results provide a simple and robust portfolio solution for a broad range of tax-conscious investors. [ABSTRACT FROM AUTHOR]

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Die Unternehmensbesteuerung (Ubg) is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Die Unternehmensbesteuerung (Ubg) is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Zeitschrift für Stiftungswesen is the property of Verlag Oesterreich GmbH and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

This article develops a new strategy for the (tax) optimization of foreign direct investments in the U.S. This strategy is particularly favorable for natural persons. By using a foreign upstream hybrid partnership, a substantial tax optimization of the current taxation of profits as well as the taxation of capital gains can be achieved. In addition, current and final losses may also be offset cross‐border to a certain extent in the case of an exemption under treaty law. This tax structuring idea is presented by way of example and explained on the basis of the country constellation U.S./Germany. [ABSTRACT FROM AUTHOR]

Copyright of Zeitschrift für Stiftungswesen is the property of Verlag Oesterreich GmbH and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Zeitschrift für Stiftungswesen is the property of Verlag Oesterreich GmbH and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

This article explores the challenges and strategies involved in implementing factor investing for taxable investors. Factor investing involves constructing portfolios based on specific characteristics to outperform passive benchmark indices. However, the trading required for factor strategies can generate significant capital gains tax liabilities, potentially offsetting the outperformance. The authors propose incorporating tax management techniques into the portfolio implementation process to capture factor premiums while mitigating tax liabilities. They introduce a framework for assessing the risk of taxes outweighing factor premiums and discuss various tax management techniques. The article emphasizes the importance of tax efficiency in factor investing and provides a practical framework for incorporating tax management into the investment process. The authors conducted simulations and found that tax-managed factor strategies can deliver pre-tax factor alphas while mitigating capital gains taxes. However, there are performance differences across strategies, and tax efficiency and implementation differences should be considered. Another document discusses the quantification of risks in equity investment management using risk metrics such as tracking error, beta exposure to factors, and expected shortfall. It provides examples based on the value strategy to illustrate these risk concepts. The document emphasizes the importance of considering factors such as dispersion, correlation, and mean returns in assessing risk. It also introduces the concepts of risk attribution and covariance-based risk contributions. The goal is to provide library patrons with a deeper understanding of the drivers of poor investment outcomes and the factors that contribute to risk in equity investments. The article discusses the impact of capital gains taxes on factor strategy alphas for taxable investors and highlights the importance of tax management techniques [Extracted from the article]

The General Tax Directorate has recently followed the courts' criteria regarding the effects of regularising transactions falling within the scope of the tax neutrality regime applicable to mergers and other reorganisations. It analyses whether the regularisation of a stock exchange transaction could lead to the taxation of deferred capital gains under the tax neutrality regime. In its consultation, the public authority clarifies that the antiabuse rule under the neutrality regime requires a comprehensive examination of the transaction and cannot be automatically triggered in the absence of valid economic reasons. Moreover, in these cases, the deferral inherent to the neutrality regime cannot constitute the tax benefit that would be removed following a regularisation by the audit and control bodies. [ABSTRACT FROM AUTHOR]

The article explores the strategic advantages, challenges, and recommendations for utilizing discretionary trusts within consolidated groups in the dynamic landscape of Australian taxation. Topics include mitigating dividend traps, enhanced asset protection, flexibility in distributions, and tax-efficient income accumulation within consolidated groups, shedding light on the complexities and pitfalls associated with discretionary trusts in this context.

The article explores the distinctions between "deferred consideration" and "earnouts" in share purchase agreements, emphasizing that deferred consideration is generally non-contingent, and delves into tax implications for sellers. Topics include the legal and tax characterization of deferred consideration, the difference between reverse earnouts and deferred consideration sale structures, and a case where the Australian Taxation Office treated an earnout as deferred consideration.

The article discusses a recent decision by the Administrative Appeals Tribunal (AAT) regarding an individual taxpayer's deductible loss on the purchase and sale of a residential property. Topics include the AAT's analysis of Mrs. Bowerman's motivations, the application of Myer Emporium principles, and considerations related to the income year for claiming the deduction.

Copyright of Zeitschrift für Stiftungswesen is the property of Verlag Oesterreich GmbH and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

The progressive harmonization of corporate financial information, based on the International Financial Reporting Standards, has moved fair value accounting (FVA) to the forefront of a debate that straddles accounting and corporate tax. Given the subjectivism that FVA may exhibit, especially when mark to market is not available and mark to model is used as in level 3 FVA, tax legislators have strongly restricted its impact on the corporate tax base. This paper argues that while the Portuguese corporate tax legislators explicitly followed this worldwide trend of restricting the tax impact of fair value to certain circumstances when market prices are observable (level 1 FVA), the corporate tax code has, nonetheless, several important avenues through which FVA influences taxable income determination. The main purpose of this paper is to present and discuss some important ways through which FVA may influence taxable income determination in Portugal, such as goodwill, impairment charges, transfer pricing, capital gains and exit taxation. Thus, the question emerges: is FVA returning through the window to impact the corporate tax base? Considering the global trends in public finance, and the need for present and future tax revenues, we believe this is an important topic to be addressed. [ABSTRACT FROM AUTHOR]

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

We discuss developments involving listed transactions, amicus briefs, tax exceptionalism, the Anti-Injunction Act, the "mailbox rule," nonrecognition provisions, income and deduction issues, FBAR penalties, basis, the shared responsibility payment and bankruptcy law, Washington's capital gains tax, and a few "way-out-there" taxpayer arguments. [ABSTRACT FROM AUTHOR]

The article focuses on the implications of contract timing on taxation, specifically in the context of capital gains tax (CGT) events and the CGT discount capital gain concession. It discusses the relevance of contract timing for events such as CGT event A1 and event D1, and emphasizes the application of general contract law principles when determining the existence of a binding contract, referencing recent legal cases to illustrate these principles.

The Australian Taxation Office (ATO) provides guidance that the value of a new crypto asset received from a chain split is not treated as either ordinary income or capital gain at the time of the split, provided the owner holds it a s a capital asset rather than in connection with carrying on a business. This article considers whether this guidance is well founded in cases where the crypto assets involved are cryptocurrency coins. In a chain split, the digital ledger on which cryptocoins are traded divides into two forks, resulting in two distinct cryptocurrencies. Each owner of a cryptocoin before the chain split ends up owning two separate coins, one of each of these cryptocurrencies. In its guidance, the ATO further provides that a chain split is generally not a capital gains tax (CGT) event unless the holder's rights and relationships with respect to both post-split coins have changed, in which case the chain split will be treated as an abandonment of the original coin (CGT event C2). In all cases, any new cryptocoin is assigned a zero-cost base, which is consistent with treating the coin as though it were found property. In this article, the authors question whether the ATO's approach is consistent with the nature of cryptocurrency chain splits and with settled tax law, arguing that the approach can lead to tax outcomes that differ significantly from economic reality. The authors suggest that the ATO may have erred by identifying either of the post-split coins as newly found and by considering the original coin to be lost or abandoned in some circumstances. The authors argue that cryptocurrency chain splits are more akin to property divisions (such as land subdivisions), and suggest that it would be more appropriate to apportion the cost base of the original coin between the two post-split coins using the split asset method applied in tax cases involving land subdivisions. This conclusion is based on a finding that the coin owner's rights and relationships with respect to both post-split coins remain unchanged from those associated with the original coin. This article's chief contribution is to explore the meaning of rights and relationships with respect to cryptocurrency and to show that, while it may be convenient to refer to one of the post-split coins as new, in fact, each post-split coin is a continuation of the original coin, much as two post-division lots of land are merely a continuation of the larger lot of land before subdivision. Both postsplit coins, like both post-division lots, literally trace their chain of title back to the original asset. The authors believe that further research may be necessary to establish how crypto assets other than cryptocoins, including non-fungible tokens, should be treated in the event of a chain split. [ABSTRACT FROM AUTHOR]

Copyright of Galician Journal of Economics / Revista Galega de Economía is the property of Universidad de Santiago de Compostela, Servicio de Publicaciones and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Many states face challenges in producing accurate forecasts of tax revenue from personal income. Using data from 1996 to 2019, we look at how growth in the various base components of personal income influence the accuracy of a state's forecast of revenue from personal income taxation. We consistently find growth in capital gains, which has the highest year-to-year volatility among personal income components, to be associated with a state underestimating its actual revenues from personal income by at least 2 percentage points. [ABSTRACT FROM AUTHOR]

This paper considers the role of capital gains taxation in enhancing tax progressivity, and argues that capital gains are the Achilles' heel of taxing the rich more effectively. We revisit the key aspects of how capital gains are taxed and address the main arguments against taxing capital gains more heavily: (i) it would discourage socially beneficial activities, such as innovation, (ii) implementing structural changes is unadministrable, and (iii) the 'lock-in' effect means that increasing the tax rate is an inefficient way to raise revenue. To address concerns with the unpopularity of taxing unrealized gains during one's lifetime and retroactive taxes, we conclude with a partial proposal for constructive realization at death that would apply only to gains accrued after a certain date, while allowing for discounted pre-payments of tax liability. [ABSTRACT FROM AUTHOR]

In the optimal design of tax reform proposals, and in decisions about when and how to recommend them, it is useful to take explicit account of issues of political feasibility. In the United States—and probably around the world—important political barriers work against the enactment of major progressive tax reforms. A close look at US poll and survey data indicates that opposition by the general public is not a significant barrier: large majorities favour progressive taxation in general and favour a number of specific progressive tax changes, including higher top personal income tax rates; higher taxes on corporations; increased taxation of realized capital gains; and taxation of unrealized gains at death. But there exist other serious political barriers against tax reform, including an institutional status quo bias that makes any major policy change (especially any progressive change) very difficult; and strong political opposition from business corporations and wealthy individuals. The best available evidence indicates that nearly all US business firms, and most multi-millionaires and billionaires, oppose practically any sort of progressive tax reform. The best evidence also indicates that these firms and individuals exercise far more influence on policy-making than ordinary citizens do. We mention some possible strategies for dealing with this problem. [ABSTRACT FROM AUTHOR]

Using anonymized administrative data on the population of UK taxpayers, we show that—in line with high-profile anecdotes about the tax affairs of the rich—effective average tax rates (EATRs) decline at the top of the distribution of income and capital gains. We also document substantial variation in EATRs within remuneration level: a quarter of those in the top 1 per cent pay headline rates, while another quarter pay at least 9pp less than the headline rate. Most of this effect is driven by the composition of remuneration, with investment income having lower tax rates and capital gains having lower rates still. If all individuals with income above £100,000 paid the headline rates, this would raise tax revenue on income and gains by £23 billion on a static basis, an increase of 27 per cent in the tax paid by this group. [ABSTRACT FROM AUTHOR]

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

The article focuses on various scenarios involving capital gains tax (CGT) and the main residence exemption, including situations where properties transition from being the family home to investment property, are used as holiday homes, are rented out and later used as a home, and the implications of divorce on jointly acquired properties.

We examine the effect of staggered changes in the state-level capital gains tax on venture capital (VC)-backed start-ups and show that an increase in the tax rate of VC firms reduces the quantity and quality of patents by the start-ups. The results are consistent with a reduction in VC firms' incentives to provide effort: increases in the capital gains tax for VC firms lead to incrementally lower innovation exchanges between start-ups in the VC firm's portfolio. VC firms also decrease the level of investment in start-ups and the size of their portfolio as well as increase the number of start-ups that they write off. [ABSTRACT FROM AUTHOR]

Prior studies of the relevance of long‐term capital gains for stock prices rely on the evidence from the 1997 tax cut in the United States. The key component of the tax‐sensitive ownership in these studies is individual ownership; its average is reported to be as high as 66.7%. The sharp increase in institutional ownership over the last two decades to more than 80% and the concomitant decline in individual ownership raises the question of whether taxes on long‐term capital gains are still relevant for stock prices. We examine stock price responses to the 2018 increase in the long‐term capital gains tax rate in India, a market where individual stock ownership is only 18.5%. Overall, the evidence provides strong support for the continued relevance of long‐term capital gains taxes for stock prices despite individual investors accounting for only a small portion of the stock ownership. [ABSTRACT FROM AUTHOR]