Tuesday, January 21, 2020

A New Global Tax Deal for the Digital Age


Lunch with RFS boss Shane Fitzsimmons: Tears on the darkest days


The commissioner talks of a childhood of family violence, the loss of his father to fire, and how volunteering kept him on the straight and narrow.



Every company needs to put leadership skills training and talent development at the top of its priority list.  And Government needs to up its investment significantly with Education adding skills training to its curriculum at some speed.
Natalie Ceeney Making Democratic Countries Great Again





Slideshare Has Become A Major Repository For Pirated Books

The more popular the book, the more pervasive the SlideShare piracy. Searches for the top five fiction and nonfiction books on the New York Times bestseller list (which includes authors ranging from Malcolm Gladwell to Delia Owens to Ronan Farrow) produce multiple pages of pirated e-book links on SlideShare for each title. – Fast Company




Shu-Yi Oei (Boston College) & Diane M. Ring (Boston College), The Importance of Qualitative Research Approaches to Gig Economy Taxation:

As the United States tax system continues to grapple with how to tax workers in the gig economy, it confronts a number of questions about the nature and composition of the sector as well as the tax issues confronted by its participants. Many of these questions have proven difficult to answer due to a lack of adequate information. But the answers are important and will shape how tax and other areas of law (such as employment law, labor law, and antitrust) respond to the gig economy. Thus, the question of how to obtain the data and information necessary to formulate sound policies for gig work is vital.


The 2020 Edelman Trust Barometerreveals that despite a strong global economy and near full employment, none of the four societal institutions that the study measures—government, business, NGOs and media—is trusted. The cause of this paradox can be found in people’s fears about the future and their role in it, which are a wake-up call for our institutions to embrace a new way of effectively building trust: balancing competence with ethical behavior…Since Edelman began measuring trust 20 years ago, it has been spurred by economic growth

Australia has slightly fewer billionaires, but their wealth is still increasing says Oxfam  


47 countries witness surge in civil unrest – trend to continue in 2020- Political Risk Outlook 2020 – “The dramatic surge in protests in 2019 has swept up a quarter of countries in its tide and sent unprepared governments across all continents reeling. According to our latest data and forecasts, the turmoil is set to continue unabated in 2020. Our quarterly Civil Unrest Index reveals that over the past year 47 jurisdictions have witnessed a significant uptick in protests, which intensified during the last quarter of 2019



This week, Mirit Eyal-Cohen (Alabama) reviews Israel Klein (Ariel University), Contemptuous Tax Reporting, 2019 Wis. L. Rev. ___ : 
Mirit-Cohen (2018)This interesting article is right down my alley, namely R&D tax incentives. Recently, legal scholars (including yours truly here and here) have questioned the justifications for the current R&D tax incentives regime and their effectiveness in inducing additional research expenditures. Every year, about 25 billion dollars of research incentives are claimed by companies. Likewise, the current R&D credit allows companies to reduce tax bills by an amount equal to 14 or 20 percent of their current year Qualified Research Expenditures. The article points out that this tax benefit combined with the U.S. self-assessment principle that encompasses only occasional ex-post audits create an incentive for managers to participate in contemptuous self-reporting, that is reporting their companies’ tax while intentionally miscategorized R&D expenditures. Moreover, the recent repeal of the corporate Alternative Minimum Tax (AMT) in the Tax Cuts and Job Act removed the limits on the extent to which taxpayers can utilize credits and deductions to lower their overall tax liability, thus created a bigger tax break for R&D while perpetuating the incentive to overstate R&D spending.



The famous and wealthy owner of the Tottenham football club is rumoured to house 400+m of art on his super yacht.

John Cochrane on wealth and taxes, overview.
Allison Christians (McGill) & Tarcisio Diniz Magalhaes (McGill), A New Global Tax Deal for the Digital Age:

The OECD is currently in the midst of a project intended to tackle the tax challenges arising from the digitalization of the economy. As laid out in Pillar 1 of its program of work released in May 2019, the goal seemed broadly to develop consensus on a new taxing right, to allow countries to tax multinationals even in the absence of traditional physical presence. Upon inspection, the plan seems to be about rebalancing taxing rights mostly among the relatively affluent OECD member states plus a few other key non-OECD states. Viewed from this perspective, the urgent effort to forge a new global tax deal for the digital age is destined to forestall a much-needed discussion on the broader distributive implications of the current global tax deal. This Article therefore critically examines the emerging tax bargain. Part I begins with a brief survey of some of the main factors that prompted the OECD to turn its attention to this topic. Part II considers the origins and development of nexus in the international tax regime, showing why this concept is amenable to broad expansion. Part III examines the range of reforms currently under consideration, arguing that the framing on digitalization misses a necessary connection to other pressing international policy programs that are also under development, most notably a global commitment to building institutions that support sustainable economic development.

Alexa, How Do I Protect My Organization’s Data From You? ... Law Technology Today: “Has Alexa infiltrated your company yet? There are 3.25 billion users of digital voice assistants in the world. It stands to reason that if you haven’t seen one of these devices on employees’ desks yet, you soon will. The industry is expected to grow to eight billion users by 2023