MLPs: how the IRS subsidizes o...

Jun 18, 2013 by

As more M.L.P.’s come to resemble normal operating companies, the tax loophole looks more like a straightforward tax subsidy for fossil fuel production. From an environmental standpoint, this is exactly backward. We should be taxing carbon production, not subsidizing it.

As with real estate investment trusts, the I.R.S. has made matters worse by carving the original loophole, brick by brick, into an opening big enough to drive an oil tanker through.

In a series of private rulings over the last few years, the I.R.S. has been exceedingly accommodating toward what counts as an energy M.L.P. The end result is that more oil and natural gas companies, and companies loosely affiliated with the industry, can legally skirt the general requirement that publicly traded entities must pay the corporate tax.

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Defining REITs

Jun 14, 2013 by

The problem is that many companies that resemble normal operating businesses now qualify as REITs.

Iron Mountain is a great example. Only on its tax return would one describe it as a real estate business. The value of the business turns on its ability to deliver information management services, including virtual and real document storage. The value of its real estate holdings is almost incidental to the business model.

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Economic Roots of Apple

Jun 10, 2013 by

My take on the Apple hearing: The hearing by the Senate Permanent Subcommittee on Investigations on Tuesday focused on Apple‘s...

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Reducing the Corporate Tax Rat...

Jun 10, 2013 by

In the paper, the authors look at statutory tax rate changes over a 12-year period in 87 countries to see how those rate changes...

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Apple’s True U.S. Tax Ra...

Jun 10, 2013 by

Here’s my suggestion. Congress should require every large American company to disclose to the public a simple number each year, which...

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Despite Tax Rules, Companies S...

Jun 10, 2013 by

  Because corporate residence is, in effect, elective, it is surprising that nearly all new companies with headquarters here...

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