Why does tax have to be so taxing? The Court revisits the Franked Investment Income litigation

Examines the European Court of Justice ruling in Test Claimants in the FII Group Litigation v Inland Revenue Commissioners (C-35/11) on whether the differential tax treatment of domestic and foreign-sourced dividends in the UK was compatible with the freedom of establishment and free movement of capital principles. Outlines its guidance on how to assess this compatibility. Considers the ruling's implications for the UK tax system, the relationship between tax sovereignty and the internal market and the third-country dimension of the free movement of capital principle.

A kettős adóztatás elkerüléséről szóló korai magyar egyezmények = Earlier tax treaties of Hungary

Ennek a dolgozatnak az a célja, hogy bemutassa Magyarország történeti kettős adóztatás elkerüléséről szóló egyezményeit. A bevezetés, az első és a második fejezet a nemzetközi adózással kapcsolatos alapfogalmakat tisztázza. A harmadik fejezet Magyarország XVII-XVIII. századi gazdasági és politikai helyzetét írja le. Az ezt követő fejezetek a világháborúk előtti, közötti és utánuk következő időszak adóegyezményeinek történetével foglalkoznak. Az egyik fejezet a KGST tagállamok által kötött kettős adóztatás elkerüléséről szóló multilaterális egyezményt tárgyalja. Az összegzésben megállapításra kerül, hogy az adóegyezmények megkötésének a múltban nem feltétlenül gazdasági okai voltak. Bizonyos esetekben sokkal erőteljesebb volt a politikai (elsősorban külpolitikai) motiváció. A tanulmány számos olyan érdekes adalékkal szolgál a Vasfüggöny előtt letárgyalt adóegyezményekről, amelyek eddig még nem kerültek publikálásra a magyar szakirodalomban. _________ This paper intends to review the history of the double taxation agreements concluded by Hungary. The introduction, the first and the second chapters clear some basic definitions in the field of international taxation. The third chapter describes the political and economic history of Hungary back in the 17-18 centuries. The next chapters deal with the tax treaties concluded before the First World War, between the two Wars and after the Second World War. One chapter touches upon the COMECON multilateral tax treaties. The paper concludes that the economic importance of old tax treaties was not always the strongest commanding force during the negotiations. Sometimes political (especially foreign policy) reasons seemed much more relevant for the treaty party countires. The paper also provides an overview of the most interesting features of the tax treaties negotiated before the fall of the Iron Curtain for the first time in the Hungarian literature.

Marketing Dynamics of a Hotel Tax: The Case of Chautauqua County, New York

Imposing a hotel tax in Chautauqua County, New York, which has natural attractions and the proximity of viable markets, might be highly likely to contribute significantly to the economic climate for the county. The authors examine the likely impact of hotel taxes, review hotel tax rates in cities across the country and in New York State, recommend revenue distribution, and propose a process by which hotel tax revenues can be equitably and efficiently disbursed

The Tax Reform Act of 1986: Impact On Hospitality Industries

In her discussion - The Tax Reform Act Of 1986: Impact On Hospitality Industries - by Elisa S. Moncarz, Associate Professor, the School of Hospitality Management at Florida International University, Professor Moncarz initially states: “After nearly two years of considering the overhaul of the federal tax system, Congress enacted the Tax Reform Act of 1986. The impact of this legislation is expected to affect virtually all individuals and businesses associated with the hospitality industry. This article discusses some of the major provisions of the tax bill, emphasizing those relating to the hospitality service industries and contrasting relevant provisions with prior law on their positive and negative effects to the industry. “On October 22, 1986, President Reagan signed the Tax Reform Act of 1986 (TRA 86) with changes so pervasive that a recodification of the income tax laws became necessary…,” Professor Moncarz says in providing a basic history of the bill. Two, very important paragraphs underpin TRA 86, and this article. They should not be under-estimated. The author wants you to know: “With the passage of TRA 86, the Reagan administration achieved the most important single domestic initiative of Reagan's second term, a complete restructuring of the federal tax system in an attempt to re-establish fairness in the tax code…,” an informed view, indeed. “These changes will result in an estimated shift of over $100 billion of the tax burden from individuals to corporations over the next five years [as of this article],” Professor Moncarz enlightens. “…TRA 86 embraces a conversion to the view that lowering tax rates and eliminating or restricting tax preferences (i.e., loopholes) “would be more economically and socially productive.” Hence, economic decisions would be based on economic efficiency as opposed to tax effect,” the author asserts. “…both Congress and the administration recognized from its inception that the reform of the tax code must satisfy three basic goals,” and these goals are identified for you. Professor Moncarz outlines the positive impact TRA 86 will have on the U.S. economy in general, but also makes distinctions the ‘Act will have on specific segments of the business community, with a particular eye toward the hospitality industry and food-service in particular. Professor Moncarz also provides graphs to illustrate the comparative tax indexes of select companies, encompassing the years 1883-through-1985. Deductibility and its importance are discussed as well. The author foresees Limited Partnerships, employment, and even new hotel construction and/or rehabilitation being affected by TRA 86. The article, as one would assume from this type of discussion, is liberally peppered with facts and figures.

Using Tax Incentives Reduces Construction Costs

Rehabilitation tax credits can save developers a significant amount of money. The author discusses the tests used to lower overall tax liability by renovating older structures.

Property Exchange Rules Offer Tax Opportunities for Hotel Owners

One strategy often overlooked by hospitality owners in developing cost-saving strategies is the use of like-kind exchanges to acquire property. The author reviews some alternative methods of like-kind exchanges, which may not only provide new business opportunities for the hospitality owner, but lucrative tax benefits as well.

Essays in book -tax income differences and analyst forecasts /recommendations

Prior research suggests that book-tax income differences (BTD) relate to both firms' earnings quality and operating performance. In this dissertation, I explore whether and how financial analysts signal the implications of BTD efficiently. This dissertation is comprised of three essays on BTD. The three essays seek to develop a better understanding of how financial analysts utilize information reflected in BTD (derived from the ratio of taxable income to book income). The first essay is a review and discussion of prior research regarding BTD. The second essay of this dissertation investigates the role of BTD in indicating the consensus and dispersion of analyst recommendations. I find that sell recommendations are positively related to BTD. I also document that analyst coverage has a positive effect on the standard deviation of consensus recommendations with respect to BTD. The third essay is an empirical analysis of analysts' forecast optimism, analyst coverage, and BTD. I find a negative association between forecast optimism and BTD. My results are consistent with a larger BTD being associated with less forecast bias. Overall, I interpret the sum of the evidence as being consistent with BTD reflecting information about earnings quality, and consistent with analysts examining and using this information in making decisions regarding both forecasts and recommendations.

2016 Road Use Tax Fund (RUTF) Study

A key component of Iowa’s transportation system is the public roadway system owned and maintained by the state, cities and counties. In order to regularly evaluate the conditions of Iowa’s public roadway infrastructure and assess the ability of existing revenues to meet the needs of the system, the Iowa Department of Transportation’s 2006 Road Use Tax Fund (RUTF) report to the legislature included a recommendation that a study be conducted every five years. That recommendation was included in legislation adopted in 2007 and signed into law. The law specifically requires the following (2016 Iowa Code Section 307.31):  “The department shall periodically review the current revenue levels of the road use tax fund and the sufficiency of those revenues for the projected construction and maintenance needs of city, county, and state governments in the future. The department shall submit a written report to the general assembly regarding its findings by December 31 every five years, beginning in 2011. The report may include recommendations concerning funding levels needed to support the future mobility and accessibility for users of Iowa's public road system.”  “The department shall evaluate alternative funding sources for road maintenance and construction and report to the general assembly at least every five years on the advantages and disadvantages and the viability of alternative funding mechanisms.” To comply with this requirement, the Iowa Department of Transportation (DOT) prepared a 2011 RUTF Study (www.iowadot.gov/pdf_files/RUTFStudy2011.pdf). This study relied heavily on the work of the Governor’s Transportation 2020 Citizen Advisory Commission (CAC), established by Governor Terry E. Branstad to assist the Iowa DOT as it assessed the condition of Iowa’s roadway system and evaluated current and future funding available to best address system needs. The 2011 RUTF Study ultimately led to the passage of Senate File 257 in the 2015 legislative session that was signed into law on February 25, 2015. The major component of this bill was the increase of the state fuel tax rate on March 1, 2015, in order to meet the critical need funding shortfall identified in the study. With the recent increase in the state fuel tax rate, jurisdictions across Iowa are now putting those additional funds into road and bridge construction projects. With one full construction season complete following the increase in funding, it is difficult to accurately assess the long-term impact on construction needs. Therefore, this 2016 RUTF Study focuses on the actions taken since the 2011 RUTF Study and on alternative funding mechanisms.

Bisphosphonate-related Osteonecrosis Of The Jaw: A Review Of The Literature.

Bisphosphonates (BPs) are a class of drugs used to treat osteoporosis and malignant bone metastasis. BPs show high binding capacity to the bone matrix, especially in sites of active bone metabolism. The American Society for Bone and Mineral Research defines BRONJ as an area of exposed bone in the maxillofacial region that has not healed within 8 weeks after identification by a healthcare provider in a patient who is receiving or has been exposed to a bisphosphonate and has not had radiation therapy to the craniofacial region. Bisphosphonate-related osteonecrosis of the jaw (BRONJ) can adversely affect quality of life, as it may produce significant morbidity. The American Association of Oral and Maxillofacial Surgeons (AAOMS) considers as vitally important that information on BRONJ be disseminated to other dental and medical specialties. The purpose of this work is to offer a perspective on how dentists should manage patients on BPs, to show the benefits of accurately diagnosing BRONJ, and to present diagnostic aids and treatments strategies for the condition.

Health-related And Socio-demographic Factors Associated With Frailty In The Elderly: A Systematic Literature Review.

Frailty is a syndrome that leads to practical harm in the lives of elders, since it is related to increased risk of dependency, falls, hospitalization, institutionalization, and death. The objective of this systematic review was to identify the socio-demographic, psycho-behavioral, health-related, nutritional, and lifestyle factors associated with frailty in the elderly. A total of 4,183 studies published from 2001 to 2013 were detected in the databases, and 182 complete articles were selected. After a comprehensive reading and application of selection criteria, 35 eligible articles remained for analysis. The main factors associated with frailty were: age, female gender, black race/color, schooling, income, cardiovascular diseases, number of comorbidities/diseases, functional incapacity, poor self-rated health, depressive symptoms, cognitive function, body mass index, smoking, and alcohol use. Knowledge of the complexity of determinants of frailty can assist the formulation of measures for prevention and early intervention, thereby contributing to better quality of life for the elderly.

Interface Between Intellectual Disability And Mental Health: Hermeneutic Review.

A literature review was conducted aiming to understand the interface between the Intellectual Disability and Mental Health fields and to contribute to mitigating the path of institutionalizing individuals with intellectual deficiencies. The so-called dual diagnosis phenomenon remains underestimated in Brazil but is the object of research and specific public policy internationally. This phenomenon alerts us to the prevalence of mental health problems in those with intellectual disabilities, limiting their social inclusion. The findings reinforce the importance of this theme and indicate possible diagnostic invisibility of the development of mental illness in those with intellectual disabilities in Brazil, which may contribute to sustaining psychiatric institutionalization of this population. 

Cervical Spine Involvement In Rheumatoid Arthritis--a Systematic Review.

Rheumatoid arthritis (RA) is a systemic chronic inflammatory disorder that can compromise the cervical spine in up to 80% of the cases. The most common radiological presentations of cervical involvement are atlantoaxial subluxation (AAS), cranial settling and subaxial subluxation (SAS). We performed a systematic review in the PubMed Database of articles published later 2005 to evaluate the prevalence, progression and risk factors for cervical spine involvement in RA patients. Articles were classified according to their level of evidence. Our literature review reported a wide range in the prevalence of cervical spine disease, probably explained by the different studied populations and disease characteristics. Uncontrolled RA is probably the main risk factor for developing a spinal instability. Adequate treatment with DMARD and BA can prevent development of cervical instabilities but did not avoid progression of a pre-existing injury. MRI is the best radiological method for diagnosis cervical spine involvement. AAS is the most common form of RA. Long term radiological follow-up is necessary to diagnosis patients with late instabilities and monitoring progression of diagnosed injuries.

[recommendations For Physical Exercise Practice During Pregnancy: A Critical Review].

Physical exercise is recommended for all healthy pregnant women. Regular practice of exercises during pregnancy can provide many physical and psychological benefits, with no evidence of adverse outcomes for the fetus or the newborn when exercise is performed at mild to moderate intensity. However, few pregnant women engage in this practice and many still have fears and doubts about the safety of exercise. The objective of the present study was to inform the professionals who provide care for Brazilian pregnant women about the current recommendations regarding physical exercise during pregnancy based on the best scientific evidence available. In view of the perception that few systematic models are available about this topic and after performing several studies in this specific area, we assembled practical information of interest to both the professionals and the pregnant women. We also provide recommendations about the indications, contraindications, modalities (aerobics, resistance training, stretching and pelvic floor training), frequency, intensity and duration indicated for each gestational trimester. The review addresses physical exercise recommendation both for low risk pregnant women and for special populations, such as athletes and obese, hypertensive and diabetic subjects. The advantages of an active and healthy lifestyle should be always reinforced during and after gestation since pregnancy is an appropriate period to introduce new habits because pregnant women are usually more motivated to adhere to recommendations. Thus, routine exams, frequent returns and supervision are recommended in order to provide new guidelines that will have long-term beneficial effects for both mother and child.