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The Impact on Charitable Classes in Dallas County, Texas, Resulting from Changes in the Tax Economics of Private PhilanthropyMcClure, Ronnie C. (Ronnie Clyde) 08 1900 (has links)
Private philanthropy is important in America. In 1985, philanthropy totaled almost 80 billion dollars. Philanthropy is partially a function of price. Absent a tax benefit, the price of charitable giving is unity. When tax benefits are available, the price of cash giving is one minus the marginal tax rate of the donor.
Philanthropy is not evenly distributed among all classes of organizations. Changes in tax cost bring about changes in the distribution of gifts among organizations. Predictions have been made of a six to twelve billion dollar decline in individual giving as a result of the Tax Reform Act of 1986. The question is, "Whose ox gets gored?"
In 1962, the Internal Revenue Service collected data directly linking itemized charitable contributions to class of donee organization. Prior works by Taussig, Schwartz, Feldstein, and Clotfelter have been principally based on this data. Their works document differing elasticities of price on charitable giving. The current research gathered 1985 data on the relationships between income, price, and charitable donee for 298 Dallas County, Texas, taxpayers.
Data was obtained from selected certified public accountants in Dallas County who prepared income tax returns for individuals as part of their practice. Two hundred fifty usable responses reflected charitable gifts.
The data collected permitted the tax benefit resulting from charitable gifts to be calculated. Income levels and marginal tax rates on those gifts were then correlated with donee organizations using multiple regression analysis.
The main effects of price and income on giving were masked by multicollinearity. The interaction effects of price and other independent variables showed little price effect on giving. Only when coupled with the income variable at income levels of $50,000 was the price effect significant.
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The Home Mortgage Interest Deduction for Federal Income Tax: A Federalist PerspectiveOrtiz, Dennis S. 08 1900 (has links)
The debate over federal income tax treatment of home mortgage interest (HMI) has largely overlooked an important, and possibly unintended political and economic consequence of our federal income tax system. The distribution of the for home mortgage interest deduction tax benefit across states is a possible missing consideration. Specifically, this study offers a federalist1 perspective on the federal income tax benefit from the deduction for HMI - one of the largest personal federal tax expenditures on the books. This dissertation analyzes current national political rhetoric from a federalist perspective. Discussion also includes background, current status, and proposed changes to the tax code for of the HMI deduction. First, a Tobit regression is used to analyze the distribution of the HMI tax benefit across states and to test for disproportionate distribution across states in benefit derived from the federal income tax deduction for home mortgage interest beyond that which is explained by income. This initial part of the study is also the precursor to a hierarchical analysis seeking to identify significant factors affecting the distribution of the benefit of the HMI deduction across states. The Ernst and Young/University of Michigan Individual Model File of 1992 tax returns is the primary data source for this initial part of the investigation. The second part of the analysis examines the effect of sets of factors in a causal hierarchy on the HMI deduction benefit. By first controlling for the effects of personal and identifiable state characteristics on HMI deduction benefit, the possible existence of a residual socio-political force is tested. The primary data sources for this part of the study are the 1990 Census of Population and Housing 5% Public Use Microsample as well as tax data extracted from the Statistics of Income, Individual Public Use Tax File, Level III Sample, as well as others. Ridge regression is used for hypothesis testing. Results indicate the existence of a significant difference in the benefit from home mortgage interest deduction across states holding income constant. This study also finds that a set of personal as well as a set of state market, legal and tax characteristics significantly influence the taxpayer's HMI deduction benefit, and that a residual difference in benefit across states after controlling for personal and identified state attributes. Future study should examine the source of residual across state differences (attributed to socio-political differences between states). Federal housing goals may be frustrated as the effective subsidy actually helps support higher home prices in areas where high housing costs may already be a barrier to potential new homeownership. The concepts and techniques applied in this study could easily be applied to other provisions of federal tax, or to any other tax system in a federation for that matter.
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Income taxes and the arts : tax expenditures as cultural policy.Schuster, J. Mark Davidson, 1950- January 1979 (has links)
Thesis. 1979. Ph.D. cn--Massachusetts Institute of Technology. Dept. of Urban Studies and Planning. / MICROFICHE COPY AVAILABLE IN ARCHIVES AND ROTCH. / Vita. / Bibliography: leaves 268-278. / Ph.D.cn
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Die steuerliche Behandlung von Humankapitalinvestitionen im Rahmen der Einkommensteuer /Rimmler, Michael Robert. January 2005 (has links) (PDF)
Univ., Diss.--Heidelberg, 2004.
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The charitable purposes exemption from income tax : Pitt to Pemsel 1798-1891 : a thesis submitted in partial fulfilment of the requirements for the degree of Doctor of Philosophy in the University of Canterbury /Gousmett, Michael. January 2009 (has links)
Thesis (Ph. D.)--University of Canterbury, 2009. / Typescript (photocopy). Includes bibliographical references (p. 581-602). Also available via the World Wide Web.
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Prohibition of wear and tear allowance on structures of a permanent natureKhwela, William 24 July 2013 (has links)
M.Comm. (South African & International Taxation) / The capital allowance mentioned in section 11(e) of Income Tax Act 58 of 1962 (“the Act”) refers to machinery, plant, implements, utensils and articles, the value of which may have diminished by reason of wear and tear or depreciation. The machinery, plant, and articles in question, often accede to other assets of a permanent nature such as immovable buildings. This is a problem in South Africa because the wear and tear allowance is lost when machinery, plant or articles lose their identities upon being absorbed into assets of a permanent nature such as a building. Buildings and other structures of a permanent nature do not qualify for the wear and tear allowance in terms of section 11(e) of the Act. This article investigates the uncertainties with regard to interpreting what constitutes “buildings, or other structures or works of a permanent nature” for the purposes of the prohibition of wear and tear allowances contained in section 11(e)(ii) of the Act.
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The proposed new gambling tax in South AfricaRoberts, Justin Esrom January 2011 (has links)
In the 2011/2012 Budget Speech delivered by the Minister of Finance, Pravin Gordhan, it was announced that a 15% withholding tax on gambling winnings above R 25 000 was to be introduced with effect from 1 April 2012. This treatise was undertaken to critically analyse the different elements of the proposed new withholding tax. It was established that the fiscus already benefits significantly from the gambling industry and levies and taxes from the gambling industry dwarf the revenue SARS collect from other forms of taxes such as Donations tax and Estate Duty tax. The necessity, therefore, of taxing gambling winnings in the hands of the individual is debatable. A comparison with the three foreign countries used by the Minister as an example of countries who have successfully implemented a withholding tax on gambling winnings exposed operational or other characteristics which bear no significant relationship to the situation in which the industry operates in South Africa. Probably the most significant difference is the fact that in the three foreign countries, losses are deductible and only the net gains are taxed. Although it iv could add to an already seemingly administrative-intensive legislation, it is submitted that taxing gambling winnings and ignoring losses suffered by gamblers will be disproportionately unfair towards the taxpayer. The many questions raised in this treatise illustrate the level of uncertainty still surrounding the new proposed gambling tax. It is hoped that communication will be provided by SARS as soon as possible to address the issues at hand. This would go a long way in ensuring that the implementation of the proposed withholding tax on gambling winnings is as smooth and efficient as possible.
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Aftrekbaarheid van omgewingsherstel uitgawes vanuit 'n belasting-oogpuntSwart, Willem Jacobus 07 October 2014 (has links)
M.Com. / Please refer to full text to view abstract
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The deductibility of indirect empowerment measures relating to black economic empowerment (BEE) in terms of the income tax actAcker, Tim 12 1900 (has links)
Thesis (MAcc)--Stellenbosch University, 2012. / ENGLISH ABSTRACT: The requirements of broad-based black economic empowerment (‘BEE’) are set
out in the BEE scorecard. When an entity incurs expenditure relating to indirect
empowerment measures (i.e. the preferential procurement, enterprise
development, skills development and socio-economic development categories on
the BEE scorecard), it is unclear whether the expenditure will be deductible for
income tax purposes (BEE Partner, 2008).
The objectives of the current study are to determine whether such expenditure is
deductible and to formulate best practice guidelines for the deduction of the
expenditure. The best practice guidelines consist of factors that should be
considered when determining whether expenditure is deductible, as well as
recommendations on how to justify that such expenditure should, in fact, be
deductible. The methodology used was to first consider the requirements of the BEE
scorecard, the types of expenditure and the reasons for incurring expenditure
towards indirect empowerment measures. The deduction of such expenditure was
then considered in a general sense and specifically for each broad category of
expenditure. Lastly, the best practice guidelines were formulated based on the
conclusions reached.
Common expenditure towards indirect empowerment measures of BEE was
grouped into broad categories. The different reasons why entities incur such
expenditure were identified, as the reason for incurring expenditure can influence
whether it is incurred in the production of income (Van Schalkwyk, 2010b:110).
It is submitted that expenditure that is excessive or that is incurred for
philanthropic purposes would not be incurred in the production of income. Four issues were identified that could preclude a deduction in terms of the general
deduction formula (section 11(a)) – notably, that expenditure has to be in the
production of income and non-capital in nature to be deductible. In addition to
section 11(a), special income tax deductions (sections 12H, 12I or 18A) and
capital allowances (sections 11(e), 13sex or 15(a)) could also possibly apply, but
only for certain types of expenditure and only in qualifying circumstances.
The conclusions drawn as to the deductibility of expenditure are summarised as a
guideline for taxpayers.
The above-mentioned conclusions, along with the literature examined, were used
to formulate general best practice guidelines. One such guideline is that the onus
is on taxpayers to show (through one of the ways suggested) that expenditure is
in the production of income. Taxpayers should also note that excessive
expenditure is not in the production of income and that certain expenditure
required by sector charters is more likely to be capital in nature. Furthermore, specific best practice guidelines were submitted for each broad
category of expenditure and relate to, for example, the applicability of the
identified special deductions and the quantification of non-monetary expenditure.
The specific best practice guidelines should be considered when incurring
expenditure in a specific category.
In summary, even though expenditure towards indirect empowerment measures
has been found to be deductible in most cases, there are exceptions of which
taxpayers should be aware. The proposed best practice guidelines include
guidance that could be considered before incurring expenditure towards indirect
BEE measures. / AFRIKAANSE OPSOMMING: Die vereistes van breë-basis swart ekonomiese bemagtiging (‘SEB’) word in die
SEB-telkaart uiteengesit. Wanneer ’n entiteit onkostes met betrekking tot indirekte
bemagtigingsmaatreëls (die telkaartkategorieë vir voorkeurverkryging, besigheidsontwikkeling,
vaardigheidsopleiding en sosio-ekonomiese ontwikkeling) aangaan,
is dit nie duidelik of sodanige onkoste vir inkomstebelasting-doeleindes aftrekbaar
sal wees nie (BEE Partner, 2008).
Die doelwitte van hierdie studie was om te bepaal of sulke onkostes
belastingaftrekbaar is en om bestepraktyk-riglyne te formuleer vir die aftrekking
van die onkostes. Die bestepraktyk-riglyne bestaan uit faktore wat oorweeg moet
word in die bepaling of onkostes belastingaftrekbaar is, sowel as aanbevelings
oor hoe aftrekbaarheid geregverdig kan word. Die studiemetodologie het eerstens ’n ondersoek behels na die vereistes van die
SEB-telkaart, die soorte onkostes sowel as die redes vir die aangaan van
onkostes wat met indirekte bemagtigingsmaatreëls verband hou. Daarna is die
belastingaftrekbaarheid van sodanige onkostes in die algemeen sowel as
spesifiek vir elke breë kategorie van onkoste oorweeg. Laastens is die
bestepraktyk-riglyne opgestel op grond van die gevolgtrekkings wat bereik is.
Algemene onkostes wat met indirekte SEB-maatreëls verband hou, is in breë
kategorieë gegroepeer. Die verskillende redes waarom entiteite die uitgawes
aangaan, is bepaal, aangesien dit kan beïnvloed of die uitgawe in die
voortbrenging van inkomste is of nie (Van Schalkwyk, 2010b:110). Daar word
aangevoer dat onkoste wat oormatige is of onkostes met betrekking tot
filantropiese doeleindes nie as deel van die voortbrenging van inkomste beskou
kan word nie. Vier kwessies is geïdentifiseer wat ’n aftrekking ingevolge die algemene
aftrekkingsformule (artikel 11(a)) kan verhoed – die belangrikste is dat die
onkostes in die voortbrenging van inkomste aangegaan moet word en nie kapitaal
moet wees om afgetrek te kan word. Benewens artikel 11(a), kan spesiale
belastingaftrekkings (artikel 12H, 12I of 18A) en kapitaaltoelaes (artikel 11(e),
13sex of 15(a)) ook moontlik geld, maar slegs vir sekere soorte onkostes en in
omstandighede wat daarvoor in aanmerking kom. Die gevolgtrekkings oor die
belastingaftrekbaarheid van onkostes word uiteindelik as ’n riglyn vir
belastingbetalers opgesom.
Bogenoemde gevolgtrekkings, tesame met die bestudeerde literatuur, is gebruik
om algemene bestepraktyk-riglyne te formuleer. Een so ’n riglyn is dat die
bewyslas op die belastingbetaler rus om (op een van die voorgestelde maniere)
aan te toon dat onkostes in die voortbrenging van inkomste aangegaan word.
Belastingbetalers moet ook daarop let dat oormatige onkostes nie as deel van die
voortbrenging van inkomste beskou kan word nie en dat sekere onkostes
ingevolge die vereistes van sektorhandveste meer waarskynlik kapitaal van aard
sal wees. Spesifieke bestepraktyk-riglyne is voorts vir elke breë kategorie van onkostes
voorgestel, byvoorbeeld met betrekking tot die toepaslikheid van die
geïdentifiseerde spesiale aftrekkings en die kwantifisering van nie-monetêre
onkostes. Hierdie spesifieke bestepraktyk-riglyne behoort in ag geneem te word
wanneer onkostes in ’n spesifieke kategorie aangegaan word.
Ter samevatting behoort belastingbetalers daarop bedag te wees dat hoewel
onkostes met betrekking tot indirekte bemagtigingsmaatreëls in die meeste
gevalle belastingaftrekbaar is, daar wel sekere uitsonderings is. Die voorgestelde
bestepraktyk-riglyne bied derhalwe leiding oor die faktore wat oorweeg kan word
voordat onkostes met betrekking tot indirekte bemagtigingsmaatreëls aangegaan
word.
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The meaning of expenditure actually incurred in the context of share-based payments for trading stock or services renderedNguta, Mbulelo January 2015 (has links)
Section 11(a) of the Income Tax Act 58 of 1962 entitles taxpayers to a deduction in respect of expenditure actually incurred, provided that all the other requirements of section 11 and section 23 of the Act have been met. A company may issue its own shares, credited as fully paid up, as a payment for trading stock or services rendered, as was the case in C:SARS v Labat Africa (2011) 74 SATC 1. The question that was raised by this decision is whether the issue of shares constitutes “expenditure” as contemplated in section 11(a) of the Act. It is trite that a share in a company is a bundle of rights which entitle the holder to dividends when declared and to a vote in shareholders’ meetings and that a share does not come into the hands of a shareholder by way of transfer from the company, but is rather created as a bundle of rights for him in the company. In C: SARS v Labat Africa, the Supreme Court of Appeal decided that to issue shares as a payment for goods is not expenditure as contemplated in section 11(a) of the Act. The Act does not define “expenditure”. It has been interpreted in certain cases as a payment of money or disbursement, while it has been interpreted as the undertaking of a legal obligation in other cases. The Labat Africa case has been criticised for its interpretation of expenditure on the grounds that it is contrary to the principle that “actually incurred” does not mean “actually paid”. This research has argued that, in the context of the Labat Africa case, which related to an issue of shares in payment for goods, Harms AP’s judgment was concerned with showing why a share issue is not expenditure. He could not have intended to deny a deduction to transactions such as credit purchases.
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