Is United States Corporate Tax Policy Outsourcing America - A Critical Analysis of the Proposed Tax Holiday for Trapped CFC Earnings

THE debate about how best to reform U.S. corporate tax policy has focused almost exclusively on making U.S. corporations more competitive globally. But the debate often glosses over tax policy\u27s effect on the ultimate beneficiaries of corporate success and failure—U.S. corporate stakeholders. The assumption often has been that healthy, competitive U.S. corporations equal healthy stakeholders—including shareholders, employees, and the U.S. populace as a whole. However, recent economic research has brought the assumption of trickle down success into question. This Article suggests an alternate path focused on enhancing the competitiveness of U.S. MNCs in the global economy while enhancing the welfare of U.S. corporate stakeholders. The Article concludes by suggesting an incremental reform to the current Subpart E regime that would allow U.S. MNCs to repatriate assets currently trapped in CECs at a low tax cost in exchange for targeted domestic re-investment commitments. This normative solution would have a substantially lower net federal budgetary cost to implement than other proposals currently circulating. [ABSTRACT FROM AUTHOR] Copyright of Villanova Law Review is the property of Villanova University School of Law and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder\u27s 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.

Putting Boomers to Pasture: Does the 2010 MIPPA Legislation Reinforce the Nursing Home Bias?

This article seeks to explore what lessons can be learned from how Medicaid end-of-life health care services are provided to the poor post-Olmstead, and how these lessons can be applied to middle class and upper middle class boomers. The article equally seeks to address how such lessons can be integrated into a meaningful dialogue with retiring boomers in a fashion that encourages discussion and decisions regarding end-of-life health care, as opposed to leaving such tough calls for surviving adult children. To this end, Part II of this article begins by examining the hurdles seniors face in accessing HCBS after the defunding of the Medigap at-home recovery option in 2010, taking into account the difficulties involved in planning for long-term care that are caused by significant cost variances depending on the community in which the care is provided. This section further explores the impact of informal care provided by family members on the cost and effectiveness of long-term care performed in the home. Part III provides a summary of the historical background of long-term care in the United States and explores the genesis and perpetuation of the bias toward providing end-of-life care in an institutional setting, despite the high costs of nursing home care, leading up to the integrated care mandate handed down by the Supreme Court in Olmstead. In Part IV, the varying degrees to which states have implemented the Olmstead mandate are examined to provide an empirical analysis of the cost-savings and reduction in nursing home admission rates that can be realized through effective and widespread implementation of HCBS programs. Spending on long-term care in states with underdeveloped HCBS programs is compared to expenditures in states offering comprehensive programs to determine the overall effect of increasing access to HCBS

Identification of hypertensive patients with dominant affective temperaments might improve the psychopathological and cardiovascular risk stratification: a pilot, case-control study.

BACKGROUND: Although mood disorders and cardiovascular diseases have widely studied psychosomatic connections, data concerning the influence of the psychopathologically important affective temperaments in hypertension are scarce. To define a possibly higher cardiovascular risk subpopulation we investigated in well-treated hypertensive patients with dominant affective temperaments (DOM) and in well-treated hypertensive patients without dominant temperaments the level of depression and anxiety, arterial stiffness and serum Brain-derived Neurotrophic Factor (seBDNF). METHODS: 175 hypertensive patients, free of the history of psychiatric diseases, completed the TEMPS-A, Beck Depression Inventory and Hamilton Anxiety Scale questionnaires in two primary care practices. Of those 175 patients, 24 DOM patients and 24 hypertensive controls (matched in age, sex and the presence of diabetes) were selected for measurements of arterial stiffness and seBDNF level. RESULTS: Beck and Hamilton scores in DOM patients were higher compared with controls. Pulse wave velocity and augmentation index did not differ between the groups while in the DOM patients decreased brachial systolic and diastolic and central diastolic blood pressures were found compared with controls. SeBDNF was lower in the DOM group than in the controls (22.4 +/- 7.2 vs. 27.3 +/- 7.8 ng/mL, p < 0.05). CONCLUSIONS: Although similar arterial stiffness parameters were found in DOM patients, their increased depression and anxiety scores, the decreased brachial and central diastolic blood pressures as well as the decreased seBDNF might refer to their higher vulnerability regarding the development not only of major mood disorders, but also of cardiovascular complications. These data suggest that the evaluation of affective temperaments should get more attention both with regard to psychopathology and cardiovascular health management

Does the Dodd–Frank Wall Street Reform Act Rein In Credit Default Swaps? An EU Comparative Analysis

The global economic crisis brought credit default swaps (CDSs) out of the shadows of Wall Street and into the public consciousness. As journalists and academics try to make sense of the economic downturn, CDSs figure prominently in their narratives. Politicians and regulators have taken aim at these complex and, what are perceived as, largely speculative financial plays, believing that this speculation was a major factor contributing to the global economic downturn. As a result, uncovered credit default swaps—and naked short selling— are frequently the target of regulators crafting prophylactic regulations designed to prevent future crises. The U.S. has taken the lead on financial reform, including regulation of CDSs. The Dodd–Frank Wall Street Reform and Consumer Protection Act, signed into law by President Obama on July 21, 2010, includes a nascent framework for comprehensive regulation of credit default swaps. This groundbreaking legislation not only significantly changes how CDSs and swaps generally are transacted and regulated, but it also mandates further study of the complex market forces responsible for the global economic downturn that are yet to be fully understood. This Article responds to the legislative call and examines if the Dodd–Frank legislation went far enough in regulating CDSs by examining alternative approaches for regulating CDSs being considered by our European counterparts

Tax Facts on Insurance & Employee Benefits

Authoritative and easy-to-use, Tax Facts on Insurance & Employee Benefits shows you how the tax law and regulations are relevant to your insurance, employee benefits, and financial planning practices. Often complex tax law and regulations are explained in clear, understandable language. Pertinent planning points are provided throughout

Tax Considerations for Real Estate Investments

Book Abstract: The Advisor’s Guide to Commercial Real Estate Investment is the only single volume A-Z guide to commercial real estate investment available today. It is an invaluable resource for anyone advising investors as well as for those seeking to increase their knowledge of real estate finance

Prospecting

The National Underwriter Sales Essentials Series combines all of the most practical, proven sales techniques advisors, agents, brokers, producers, sales managers or agency owners need to convert prospects into customers, win new business, and to grow sales. The Life & Health Sales Essentials focuses on the selling skills and techniques essential to achieving success—prospecting for new business and the demands of running an agency

Tax Facts on Insurance & Employee Benefits

Authoritative and easy-to-use, Tax Facts on Insurance & Employee Benefits shows you how the tax law and regulations are relevant to your insurance, employee benefits, and financial planning practices. Often complex tax law and regulations are explained in clear, understandable language. Pertinent planning points are provided throughout