Retrospective Capital Gains Taxation in a Dynamic Stochastic World

Menoncin, Francesco; Panteghini, Paolo M.

doi:10.1628/001522110x534835

Cited by 2 publications

(2 citation statements)

References 15 publications

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“…The conceptual basis for the approach is based on the notion that the risk-adjusted tax liability on the risk premium should be net zero, since income tax reduces both net tax gains and losses (assuming tax losses are deductible). A weakness is that the retrospective taxation approach may be administratively burdensome, while requiring large-scale market coordination and information sharing [39].…”

Section: Retrospective Taxationmentioning

confidence: 99%

“…Derivatives product valuation can be opaque and notably fluctuate, which makes taxing derivatives challenging, particularly under a traditional tax regime [40]. One possible solution is utilizing a mark-to-market approach, whereby for tax purposes, the gain/loss (calculated as the differential between the derivatives' market value and cost basis) would be recognized by the asset holder (at the end of a specified tax period, as it was sold) [41]. From a cost basis perspective, the derivative instrument would be adjusted (as a gain or less).…”

Section: Mark-to-marketmentioning

confidence: 99%

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Derivatives as Technological Disruption: A Conceptual Approach on Complex Global Financial Instrument Innovation and Related Tax Policy Tool Responses

Kim¹

2021

ujaf

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Derivatives can be embedded in financial engineered structures involving one or more conduit entities and jurisdictions. Increased innovation led to an emergent market view that assets can be both de-and re-composable, with each iteration version being tradable "aspect[s] of assets" in the marketplace. Conceptual methodology of this article provides a conceptual tax policy analysis arguing that derivatives instrument innovation poses several significant challenges to the traditional tax system. Such factors must be carefully weighed by policymakers, given their respective specific market dynamics and tax objectives, leading to the conclusion that not one approach represents a policy panacea to derivatives financial instruments. This article provides a conceptual tax policy analysis arguing that derivatives instrument innovation poses several significant challenges to the traditional global tax system, which has been traditionally predicated on a clear-cut demarcation regarding: (1) asymmetric tax treatment between debt and equity; (2) the timing rule in terms of income recognition for tax purposes (e.g. accrual versus realization); and (3) income characterization (e.g. ordinary income versus capital gains). The conceptual tax policy responses, including anti-avoidance measures, mark-to-market, bifurcation, integration, and various information-sharing regimes, have their benefits and weaknesses.

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Section: Retrospective Taxationmentioning

confidence: 99%

Section: Mark-to-marketmentioning

confidence: 99%

Derivatives as Technological Disruption: A Conceptual Approach on Complex Global Financial Instrument Innovation and Related Tax Policy Tool Responses

Kim¹

2021

ujaf

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Is analytical tax research alive and kicking? Insights from 2000 until 2022

Niemann

Sailer

2023

J Bus Econ

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This literature review evaluates the development and impact of analytical tax research (ATR) from 2000 until 2022. Based on 345 research papers, we (1) identify emerging and declining research topics in the area of ATR, (2) examine the trends in publication outlets and author teams, and (3) analyze citation metrics at both the level of articles and authors to measure perception and impact of ATR. First, we find that rather new topics, such as the impact of taxation on entrepreneurship, innovation and R&D, have begun to attract attention. Second, tax journals are not the preferred outlet for ATR and author teams exhibit a decreasing gender imbalance. Third, citation metrics are highly centered on specific publications and individual authors. Moreover, publications that appeared in economics and finance journals generate disproportionately large citation numbers compared to those that were published in tax, accounting and business research journals. Authors from Anglo-American institutions have significantly more citations than researchers from German-speaking countries. We find that ATR does not form a closed community. It unites researchers from different backgrounds based on their— sometimes nonrecurring—thematic interest in the effects of taxation on economic decisions.

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Retrospective Capital Gains Taxation in a Dynamic Stochastic World

Cited by 2 publications

References 15 publications

Derivatives as Technological Disruption: A Conceptual Approach on Complex Global Financial Instrument Innovation and Related Tax Policy Tool Responses

Derivatives as Technological Disruption: A Conceptual Approach on Complex Global Financial Instrument Innovation and Related Tax Policy Tool Responses

Is analytical tax research alive and kicking? Insights from 2000 until 2022

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