HUD guarantee of tax-exempt hospital financing : hearing before the Subcommittee on Housing and Community Development of the Committee on Banking, Finance, and Urban Affairs, House of Representatives, Ninety-sixth Congress, first session, May 17, 1979.

"Serial no. 96-21."

Tax reform proposals : hearing before the Committee on Finance, United States Senate, Ninety-ninth Congress, first session, September 24, 1985 : tax-exempt bonds.

Shipping list no. 86-321-P.

Variables affecting government debt: A comparison of certificates of participation, tax -exempt revenue bonds and tax -exempt general obligation bonds

This dissertation analyzed and compared variables affecting interest rate and yield of certificates of participation, tax-exempt revenue bonds and tax-exempt general obligation bonds. The study employed qualitative and quantitative analysis methods. ^ Qualitative research methods included surveys, interviews and focus groups. The survey solicited debt load information from 67 Florida school districts (21 responded) and addressed the question which districts used certificates of participation and why. Eight individuals with experience dealing with all three debt instruments were interviewed. A follow-up focus group of six school district financial officers gathered additional data. Results from the qualitative methods revealed school districts used certificates of participation based on millage authority amount available relative to overall tax base. Also identified was the belief of a significant difference in certificates of participation costs and the other two debt instrument types. ^ The study's quantitative methods analyzed 1998 and 1999 initial issues of Moody's AAA rated certificates of participation, tax-exempt revenue bonds and tax-exempt general obligation bonds. Through an analysis of covariance (ANCOVA), the study examined interest rates and yields while controlling for the covariates of credit enhancement, issue size, and maturity date. The analysis identified no significant difference between interest rates of certificates of participation and tax-exempt general obligation bonds (p < 0.05). There was a significant difference between interest rates of tax-exempt revenue bonds and tax-exempt general obligation bonds. This study discerned no significant difference between yield on certificates of participation and tax-exempt general obligation bonds. It identified a difference in yield between both certificates of participation and tax-exempt general obligation bonds compared with tax-exempt revenue bonds. ^ The study found COPs to have lesser overall costs than RV bonds. COPs also have a quicker entry into the market resulting in construction cost savings. The study found policy implications such as investment portfolio limitations and public choice issues about using COPs as a mechanism to grow government. ^

The tax-exempt financing of student loans.

Item 1005-C

Discriminatory religious schools and tax exempt status.

Item 288-A-5

The Suitability of tax-exempt tuition investment plans for Illinois higher education /

Caption title.

Tax administration : tax law compliance of churches and tax-exempt religious organizations /

"GAO/GGD-88-84."

Handbook for industrial development financing /

"Prepared ... by Charles P. Carlson and Jean Hommerding."

The Definition of Charity and its Nexus with Tax Preference Issues

Charity, since the Reformation, has been secularised to the extent that the continued use by the courts of analogies to a four hundred year old statute in order to determine charitable purpose with respect to tax exempt status, is giving rise to absurd situations. Tax exempt status is generally assigned by an agent of the government, for example the Inland Revenue Department in New Zealand, without any evaluation of the impact of the activities of the charitable organisation on social or economic policies. It is only when the activities of the charitable organisation are challenged in the courts, that the charitable organisation may lose its privileged position. From this brief analysis, it can be seen that the situation which is developing is a classic case of 'putting the cart before the horse'. A recent New Zealand case demonstrates the folly of assigning tax exempt status without first having examined the charitable purposes of the trust, and without having conjointly undertaken an evaluation of the social and economic impact of that charitable organisation. It is apparent that there is a need for substantial changes in charity law, with respect to charitable purpose and fiscal issues, in today's social and economic climate.

Does charity begin and end at home for tax exemptions?

Charitable organisations have remained exempt from income tax in Australia since the first comprehensive state income tax legislation in 18841 through to the current Income Tax Assessment Act 1977. The charitable exemption was also part of the English income tax legislation from its inception in 1799. The Federal Treasurer has released exposure draft legislation which seeks to remove taxation exemptions from some tax exempt organisations that perform any of their activities outside Australia or make trust distributions overseas. The proposed legislation is in response to alleged tax avoidance arrangements which involve tax exempt organisations and charitable trusts. The paper begins by describing the current charity tax exemption provisions under the Income Tax Assessment Act (ITAA). It then turns to tracing the background policy history of the amendments which appear to be at odds with the form and intent of the proposed provisions. The proposed amendments and their practical consequences are then closely scrutinised and found wanting in a number of respects. Alternative strategies are suggested to arrive at an equitable solution to the avoidance mischief.

Black fella land – white fella tax : changing the CGT implications of aboriginal/native title

The taxation of aboriginal/native title payments gives rise to a number of complex and difficult legal and policy issues. Reform measures announced on 13 February 1998 by the then Federal Treasurer and Attorney-General did not address the possible capital gains tax (‘CGT’) implications and even those relating to ordinary income under s 6-5 Income Tax Assessment Act 1997 (Cth) remain unimplemented. The much anticipated Report of the Native Title Payments Working group (6 February 2009), while primarily focusing on non-taxation issues, also recognises the need for taxation reform and makes some recommendations in regard to such. Most recently, on 18 May the Assistant Treasurer, Senator Nick Sherry, the Minister for Families, Housing, Community Services and Indigenous Affairs, Jenny Macklin, and the Attorney General, Robert McClelland, announced the commencement of a national consultation on the tax treatment of native title, including the interaction of native title, Indigenous economic development and the tax system. The Assistant Treasurer recognised the need for “greater clarity and increased certainty for native title holders on how the tax system and native title interact.” At the same time, they released a paper entitled Native Title, Indigenous Economic Development and Tax to guide the national consultation. The proposed measures considered in the paper, including exempting Native title payments and/or creating a new tax exempt Indigenous Community Fund, provide a welcome step towards reform in this area. This article is part of a broader research project that explores the CGT implications of aboriginal/native title. While these provisions impact on both Indigenous traditional owners and relevant payers, such as mining companies, the focus in the project is particularly on the CGT implications for the traditional owners. This first part of the project examines the status of aboriginal/native title and incidental/ ancillary rights as CGT assets. The broader research project will then build on this analysis in the context of relevant CGT events. As the preliminary findings in this article evidence the CGT implications of aboriginal/native title are far from certain. The application of CGT to aboriginal/native title raises more issues than it answers. The key reason is that the current law is entirely unsuitable to communally held inalienable aboriginal/native title. Nevertheless, it will be seen that it is arguable that aboriginal/native title and/or incidental rights are post-CGT assets and acts in relation to such could trigger a CGT event with tax implications for the traditional owners. It will be suggested that these current tax provisions provide a very pertinent example where the law operates as a blunt tool that does not appropriately promote justice and reconciliation. To tax Indigenous communities as a result of acts that extinguish or impair their traditional ownership is incongruous. A specific provision(s) should be included in the capital gains provisions to ensure any such payments are exempt from taxation. This is not only fair given the history of uncompensated extinguishment of aboriginal title Australia, but also promotes the ability of Indigenous communities to optimise the financial benefits stemming from aboriginal/native title agreements.

Tax reform proposals. hearing before the Committee on Finance, United States Senate, Ninety-ninth Congress, first session, June 25, 1985.

Shipping list number: 86-152-P.

Earnings management in response to the introduction of the Australian gold tax

Earnings from gold mining in Australia remained tax-exempt for almost seven decades until January 1, 1991. In the early 1980s, rapid economic prosperity induced by escalated gold prices brought the Australian gold-mining industry under intense political scrutiny. Using a variant of the modified Jones model, this paper provides evidence of significant downward earnings management by Australian gold-mining firms, which is consistent with their attempts to mitigate political costs during the period from June 1985 to May 1988. In contrast, test of earnings management over a similar period in a control sample of Canadian gold-mining firms produced insignificant results. Further, empirical results are robust to several sensitivity tests performed. During the period from June 1988 to December 1990, the Australian firms were found to have engaged in economic earnings management. This is consistent with the sample firms' incentive of maximizing economic earnings immediately prior to the introduction of income tax on gold mining. The findings of this study help to understand the impact of earnings management on the efficient resource allocation in an economy. They also contribute toward understanding the linkage between regulation of accounting for special purposes and general-purpose financial. reporting.

Frameworks for Systemic and Structural Analysis of Financial Innovations in Infrastructure

Financial innovations have emerged globally to close the gap between the rising global demand for infrastructures and the availability of financing sources offered by traditional financing mechanisms such as fuel taxation, tax-exempt bonds, and federal and state funds. The key to sustainable innovative financing mechanisms is effective policymaking. This paper discusses the theoretical framework of a research study whose objective is to structurally and systemically assess financial innovations in global infrastructures. The research aims to create analysis frameworks, taxonomies and constructs, and simulation models pertaining to the dynamics of the innovation process to be used in policy analysis. Structural assessment of innovative financing focuses on the typologies and loci of innovations and evaluates the performance of different types of innovative financing mechanisms. Systemic analysis of innovative financing explores the determinants of the innovation process using the System of Innovation approach. The final deliverables of the research include propositions pertaining to the constituents of System of Innovation for infrastructure finance which include the players, institutions, activities, and networks. These static constructs are used to develop a hybrid Agent-Based/System Dynamics simulation model to derive propositions regarding the emergent dynamics of the system. The initial outcomes of the research study are presented in this paper and include: (a) an archetype for mapping innovative financing mechanisms, (b) a System of Systems-based analysis framework to identify the dimensions of Systems of Innovation analyses, and (c) initial observations regarding the players, institutions, activities, and networks of the System of Innovation in the context of the U.S. transportation infrastructure financing.

Drivers of Innovation In Financing Transportation Infrastructure: A Systemic Investigation

Traditional methods of financing infrastructure, which include gas taxation, tax-exempt bonds, and reserve funds, have not been able to meet the growing demand for infrastructure. Innovative financing systems have emerged to close the gap that exists between the available and needed financing sources. The objective of the study presented in this paper is to assess determinants of innovative financing in the U.S. transportation infrastructure using a systemic approach. Innovation System of Systems approach is adopted for systemic assessment and a case-based research approach is utilized to explore the constituents of innovative financing for U.S. transportation infrastructure. The findings, which include constructs regarding the players, practices, and activities are used to create a model to enable understanding the dynamics of the drivers and inhibitors of innovation and, thus, to derive implications for practice. The model along with the constructs provides an analytical tool for practitioners in the U.S. transportation infrastructure.