Boston University. University Professors Program Senior theses. / PLEASE NOTE: Boston University Libraries did not receive an Authorization To Manage form for this thesis. It is therefore not openly accessible, though it may be available by request. If you are the author or principal advisor of this work and would like to request open access for it, please contact us at open-help@bu.edu. Thank you. / 2031-01-02

Thesis (M.S.)--Boston University

Thesis (LL. M.)--Judge Advocate General's School, U.S. Army, 1971. / "March 1971." Typescript. Includes bibliographical references. Also issued in microfiche.

Thesis (M. Phil.)--University of Hong Kong, 200 . / Title proper from title frame. Also available in printed format.

This thesis offers a new rationale that helps explain the phenomena of elective provisions in tax law. I analyze tax elections with reference to a particular election offered to individual taxpayers —the choice to itemize expenses or to take the standard deduction to determine taxable net income under section 63(e) of the Internal Revenue Code. I make three arguments concerning the section 63(e) election that are relevant to evaluating tax elections more generally. First, the ability to itemize deductions can be seen as having an efficiency rationale in addition to its more well-recognized horizontal equity rationale. For taxpayers with lower incomes, the election to itemize acts as a screen that reveals the taxpayer’s unobservable cost-type to the government and allows the income tax to be more optimally “tailored” in the direction of a first-best lump sum tax by lowering itemizers’ marginal tax rates. Second, I show that the elective standard deduction introduced in 1944 can be viewed as a mechanism that bolsters the separating function of the election by reducing the itemizing propensity of would-be tax avoiders and low-ability taxpayers on the boundary between itemizing and not itemizing, while saving government enforcement and taxpayer compliance costs. Third, I argue that one of the drawbacks of using elective provisions such as section 63(e) to optimally tailor the income tax—deliberation costs borne by lower-income taxpayers who are uncertain about whether they should make the election—can be mitigated by viewing elections as call options written by the government in favor of the taxpayer. By structuring the election within a real option framework, the taxpayer will have higher net utility with no loss in equity as compared to an election structured outside the real-option framework. The flexible election rules of section 63(e) comport with this utility-enhancing real option approach. Moreover, the real option analysis suggests that little-noticed details of tax elections more generally may have more important effects on their efficiency than previously recognized.

This thesis offers a new rationale that helps explain the phenomena of elective provisions in tax law. I analyze tax elections with reference to a particular election offered to individual taxpayers —the choice to itemize expenses or to take the standard deduction to determine taxable net income under section 63(e) of the Internal Revenue Code. I make three arguments concerning the section 63(e) election that are relevant to evaluating tax elections more generally. First, the ability to itemize deductions can be seen as having an efficiency rationale in addition to its more well-recognized horizontal equity rationale. For taxpayers with lower incomes, the election to itemize acts as a screen that reveals the taxpayer’s unobservable cost-type to the government and allows the income tax to be more optimally “tailored” in the direction of a first-best lump sum tax by lowering itemizers’ marginal tax rates. Second, I show that the elective standard deduction introduced in 1944 can be viewed as a mechanism that bolsters the separating function of the election by reducing the itemizing propensity of would-be tax avoiders and low-ability taxpayers on the boundary between itemizing and not itemizing, while saving government enforcement and taxpayer compliance costs. Third, I argue that one of the drawbacks of using elective provisions such as section 63(e) to optimally tailor the income tax—deliberation costs borne by lower-income taxpayers who are uncertain about whether they should make the election—can be mitigated by viewing elections as call options written by the government in favor of the taxpayer. By structuring the election within a real option framework, the taxpayer will have higher net utility with no loss in equity as compared to an election structured outside the real-option framework. The flexible election rules of section 63(e) comport with this utility-enhancing real option approach. Moreover, the real option analysis suggests that little-noticed details of tax elections more generally may have more important effects on their efficiency than previously recognized.

Historically, Chinese immigrants to the United States are a special group. They were or almost were banned from 1882 to 1968. Since in 1968 the United States abolished national origin quotas and eliminated national, race, or ancestry as a basis for immigration, thousands of Chinese immigrants came to the United States. The total population of Chinese immigrants to the US between 1980 and 2002 was 911,220, whereas it was 136,843 between 1891 and 1979. Not only did the population of Chinese immigrants have great change, the quality of Chinese immigrants also had substantial difference from those immigrated in the last century. However, there are very limited literatures focusing on the dynamics of Chinese immigration in these twenty years, which is the most important time period for Chinese immigration. The following study tries to describe the dynamics of Chinese immigration to the United States between 1980 and 2002; and analyze the influence of the American immigration laws on Chinese immigration. The dynamics of Chinese immigrants are described and analyzed by different migration categories. Other social and economic factors are added to comprehensively understand the change of Chinese immigration.

Univ., Diss.--Paris, 2004.

Univ., Diss.--Paris, 2002.

Thesis (doctoral)--Universität, Kiel, 2001. / Includes bibliographical references.