Book Review

This slim volume\u27 is for the international tax connoisseur. The author, an English barrister and member of the Inner Temple and Gray\u27s Inn, has designed his book for tax professionals already expert in their own jurisdictions who seek information on the tax systems of other countries so that they can take advantage of multijurisdictional planning. Because he assumes his readers know the rudiments of international tax principles, the author explores more innovative advanced techniques. With his British perspective and evident familiarity with the United Kingdom and continental tax systems, he suggests many approaches that United States authors frequently omit because they are not feasible under United States law. As a consequence, his book is of particular interest to those tax attorneys, whether practicing overseas or in the United States, who represent foreign clients that can legitimately arrange their affairs to achieve tax objectives free from United States legal constraints

Tax Expenditures and Tax Reform

This Review will focus primarily on the conceptual issues affecting the composition of the tax expenditure list and their relevance to current proposals for new tax legislation. In this context,the tax expenditure theory has been preeminently successful in shaping tax reform. The Review will not delve into the other aspect of Surrey\u27s thesis, which calls for executive and congressional action to alter the budget procedure by integrating direct spending programs with the indirect tax expenditure programs and by adopting one amalgamated budget for the purpose of controlling overall federal spending. This facet of the Surrey thesis has not yet gained widespread congressional acceptance on the practical level.For those concerned with tighter control of the federal budget to reduce the deficit, however, this latest work amply describes and persuasively advocates the value of such an integrated budget policy

International Tax Evasion: Spawned in the United States and Nurtured by Secrecy Havens

The United States system of income taxation is predicated upon the voluntary self-assessment and payment of tax. Voluntary compliance, in turn, depends upon the confidence of United States citizens that the taxation system is basically fair, that the tax burden essential to maintain the government is shared by all in proportion to their net income, and that those who cheat are discovered and prosecuted. Circumstances that allow certain taxpayers to escape their proper tax liability successfully tempt others to seek tax evasion devices for themselves, and, more importantly, demoralize the conscientious majority who pay their just share of taxes but also perceive the system as unfair. One cause of the widespread erosion of confidence in the equity of the United States income tax system is the recent spurt in tax evasion schemes utilizing foreign haven secrecy laws to escape detection by United States tax officials... This Article will not explore these definitional refinements, but will focus on certain schemes at one end of the spectrum that are clearly illegal. To illustrate the flagrancy of international tax fraud schemes, the Article will first discuss one particular device: the use of false foreign addresses for the receipt of United States investment income that aids the evasion of tax liability by enabling United States residents to masquerade as foreign residents and foreign persons to pose as residents in preferentially-treated foreign jurisdictions. The Internal Revenue Code sections facilitating the successful operation of this device will be explored: (1) section 861 excludes from United States income tax all interest earned on deposits with United States banks and savings and loan institutions as long as that interest is paid to a foreign investor not doing business within the United States, and (2) sections 1441 and 1442 reduce or eliminate the United States thirty percent withholding tax on portfolio income remitted to residents of countries that have bilateral tax treaties with the United States. The Article next will examine the bank and commercial secrecy laws of representative countries to ascertain, in a broader context, the manner in which United States investigations of a variety of fraudulent tax evasion practices are blocked. The Article also will review and evaluate the recent major steps taken by the Treasury Department, the judiciary, and Congress to repulse this assault on the integrity of the tax system. Finally, the Article will conclude with recommendations for additional proposals to consider

BOOK REVIEWS

The Politics of Justice: Lower Federal Judicial Selection and the Second Party System - Book Author: Kermit L. Hall; Book Reviewed by Lawrence M. Friedman In The Politics of Justice, Kermit L. Hall, a history professor at Wayne State University, takes a look at the way Presidents from Jackson through Buchanan picked judges for the federal district courts and for the territories. There were 240 such appointments during the period studied... There is something of a literature on the selection process, although Hall\u27s book does fill a rather glaring hole. The tale Hall tells rings true if we ignore a few overripe conclusions... We have activist courts, and an intensely political way of choosing judges. These two aspects of American law are certainly not unrelated. They fit each other like hand and glove. Through along, intricate historical dance of fate, they have become totally intertwined, and are now inseparable. How this came about and grew is an important part of our history, and The Politics of Justice makes a definite contribution to the telling. Must Corporate Income Be Taxed Twice? - Reviewed by Allaire Urban Karzon This study by Charles E. McLure, Jr. originated from a 1977 conference at the Brookings Institution,\u27 which focused on the technical and administrative problems that would be encountered if this country were to integrate in any form the corporate and individual income taxes. Must Corporate Income Be Taxed Twice? is a feasibility study of integration in practice, not a policy evaluation of the social desirability of integration... Before closing, some minor flaws in the book must be mentioned. Parts of its analysis are needlessly repetitive. McLure\u27s style is not crisp. There is not sufficient recognition of the criticism, expressed mainly by the legal profession, that the proposed tax reforms discussed by McLure would introduce great and perhaps unjustified complexity to the Internal Revenue Code.\u27 To some, reforms that are comprehensible only to technicians are not reforms. To some, simplification of the tax laws and certainty of consequences for taxpayers are objectives greatly to be desired... McLure\u27s review of the major questions that remain unanswered relating to the shareholder credit method, especially in the international context, leads to the inescapable inference that its adoption at this time would be premature. There are too many pitfalls that an uninformed, precipitous legislative move could unwittingly create

Discrimination of multisyllabic sequences by young infants

This paper is a review of a study to determine whether the exaggerated suprasegmentals of infant-directed speech facilitates speech perception of infants as opposed to adult-directed style of speech

Phenotypic characteristics of early Wolfram syndrome

BACKGROUND: Wolfram Syndrome (WFS:OMIM 222300) is an autosomal recessive, progressive, neurologic and endocrinologic degenerative disorder caused by mutations in the WFS1 gene, encoding the endoplasmic reticulum (ER) protein wolframin, thought to be involved in the regulation of ER stress. This paper reports a cross section of data from the Washington University WFS Research Clinic, a longitudinal study to collect detailed phenotypic data on a group of young subjects in preparation for studies of therapeutic interventions. METHODS: Eighteen subjects (ages 5.9–25.8, mean 14.2 years) with genetically confirmed WFS were identified through the Washington University International Wolfram Registry. Examinations included: general medical, neurologic, ophthalmologic, audiologic, vestibular, and urologic exams, cognitive testing and neuroimaging. RESULTS: Seventeen (94%) had diabetes mellitus with the average age of diabetes onset of 6.3 ± 3.5 years. Diabetes insipidus was diagnosed in 13 (72%) at an average age of 10.6 ± 3.3 years. Seventeen (94%) had optic disc pallor and defects in color vision, 14 (78%) had hearing loss and 13 (72%) had olfactory defects, eight (44%) had impaired vibration sensation. Enuresis was reported by four (22%) and nocturia by three (17%). Of the 11 tested for bladder emptying, five (45%) had elevated post-void residual bladder volume. CONCLUSIONS: WFS causes multiple endocrine and neurologic deficits detectable on exam, even early in the course of the disease. Defects in olfaction have been underappreciated. The proposed mechanism of these deficits in WFS is ER stress-induced damage to neuronal and hormone-producing cells. This group of subjects with detailed clinical phenotyping provides a pool for testing proposed treatments for ER stress. Longitudinal follow-up is necessary for establishing the natural history and identifying potential biomarkers of progression

Unexpected combination of acute croup and myocarditis: Case report

BACKGROUND: Lower vaccination coverage among foreign-born children is of concern because they live in households and communities characterized by more intense exposure to infectious diseases. Because of their higher prevalence rates, there is an increasing occurrence of infectious diseases imported into developed countries. This case report emphasizes the emerging necessity for new clinicians and pathologists of having competence with old infectious disease pathology. CASE PRESENTATION: A three and a half year old girl, who presented with croup history of 5 days and has been in severe respiratory distress, was admitted to the Pediatric Intensive Care Unit in shock and acute respiratory failure. The patient was immediately intubated, and a grayish nonadherent membrane extending through the glottis down into the larynx was apparent during the procedure. Echocardiographic findings, which were consistent with acute myocarditis, confirmed poor left ventricular contractility despite escalating high doses of inotropes. Autopsy showed numerous strains of toxigenic corynobacterium diphtheriae, which also grew on the Loeffler cultures of membranes received during the intubation. CONCLUSION: It is critical that new generations of clinicians and bio-pathologists not only be trained in the subspecialty of infectious disease pathology, but that they also be willing participants in the diagnosis and investigation of infectious diseases