Bibliographies thématiques / Tax Reform Act of 1969 (United States)

Littérature scientifique sur le sujet « Tax Reform Act of 1969 (United States) »

Auteur : Grafiati
Publié le 26 juillet 2024
Mis à jour le 27 juillet 2024

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Articles de revues sur le sujet "Tax Reform Act of 1969 (United States)"

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Mozumi, Seiichiro. « Tax Expenditures and the Tax Reform Act of 1969 in the United States ». Social Science History 46, no 1 (2022) : 93–118. http://dx.doi.org/10.1017/ssh.2021.41.

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AbstractIn the United States, tax favoritism—an approach that has weakened the extractive capacity of the federal government by providing tax loopholes and preferences for taxpayers—has remained since the 1930s. It has consumed the amount of tax revenue the government can spend and therefore weakened the possibility of the redistribution of fiscal resources. It has also made the federal tax system complicated and inequitable, resulting in undermining taxpayer consent. Therefore, since the 1930s, a tax reform to create a simple, fair, and equitable federal income tax system with the capacity to raise revenue has been long overdue. Many scholars have evaluated the Tax Reform Act of 1969 (TRA69), which Richard M. Nixon signed into law on December 30, 1969, as one of the most successful steps toward accomplishing this goal. This article demonstrates that TRA69 left tax favoritism in the United States. Furthermore, it points out that TRA69 turned taxpayers against the idea of federal taxation, a shift in public perception that greatly impacted tax reform in the years to follow.
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Graetz, Michael J. « Tax Reform Unraveling ». Journal of Economic Perspectives 21, no 1 (1 janvier 2007) : 69–90. http://dx.doi.org/10.1257/jep.21.1.69.

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The Tax Reform Act of 1986 was widely heralded as the most significant change in our nation's tax law since the income tax was extended to the masses during World War II. It was the crowning domestic policy achievement of President Ronald Reagan, who proclaimed it “the best antipoverty measure, the best pro-family measure, and the best job-creation measure ever to come out of the Congress of the United States.” The law's rate reductions and base broadening reforms were mimicked throughout the countries belonging to the OECD. Even at the time, however, reading the paeans to this legislation was like watching a Tennessee Williams play: something was terribly wrong, but nobody was talking about it. Two decades later, the changes wrought by the 1986 act have proven neither revolutionary nor stable. Tax experts now regard the 1986 act as a promise failed. The public seems to agree, and considerable public support exists for a “flat tax” or a national sales tax to replace the income tax. I shall examine the most important individual and corporate income tax changes since 1986, before turning to proposals for restructuring the nation's tax system.
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Aksenov, P. A. « TRUMP’S TAX REFORM AND AMERICAN BUSINESS ». International Trade and Trade Policy, no 2 (6 juillet 2018) : 91–103. http://dx.doi.org/10.21686/2410-7395-2018-2-91-103.

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The key aim of the Trump’s large-scale tax reform is to stimulate economic growth by lowering tax rates and providing tax deductions. The article examines the impact of the Tax Cuts and Jobs Act on American business and macroeconomic indicators. Reduced tax rates create significant advantages for companies doing business in the United States. Companies, primarily small businesses, expected to use additional cash for capital investments and development. Lowering tax rates will attract large corporations to invest in opening new facilities in the United States. The author analyzed the expert assessments and US GDP growth forecasts in the current and alternative scenario, as well as the impact of the Act on the growth of budget expenditures. Reform requires significant expenses and will cause budget deficit and public debt growth in the coming years, which can completely neutralize the positive effects at the micro level in the long term. However, tax incentives trigger market growth mechanisms in the economy, which helps to make the problem of growing public debt manageable and to overcome cyclical economic crises with less losses.
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McKenzie, Ken, et Michael Smart. « Policy Forum : Business Tax Reform in the United States and Canada ». Canadian Tax Journal/Revue fiscale canadienne 67, no 1 (avril 2019) : 57–66. http://dx.doi.org/10.32721/ctj.2019.67.1.pf.mckenzie.

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The authors examine some of the key features of the US Tax Cuts and Jobs Act (TCJA) and discuss the implications for Canadian corporations and government revenues. They show that the tax advantage that Canada enjoyed prior to the TCJA has declined significantly, in terms of both statutory and effective (marginal and average) tax rates. They discuss the economic effects of possible responses to the TCJA by Canadian governments, including cutting statutory rates and accelerating tax depreciation deductions. Looking ahead, the authors argue that it would be preferable to focus on a more fundamental tax reform based on the taxation of economic rents.
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Moss, Charles B., Ronald P. Muraro et William G. Boggess. « Distortionary Impacts of the 1982 and 1986 U.S. Tax Codes on Capital Investments : A Case Study of Investment in Orange Groves ». Journal of Agricultural and Applied Economics 21, no 2 (décembre 1989) : 107–15. http://dx.doi.org/10.1017/s0081305200001229.

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AbstractThe 1980s have been a period of dramatic change for the income tax code in the United States. Although numerous modifications were considered in policy deliberations, two key goals, the reduction of the importance of tax considerations in investment decisions and tax simplification, emerged from the discussion and guided drafting of the 1986 Tax Reform Act. This study examines the importance of tax considerations in investment decisions under the provisions of the Tax Reform Act of 1986 and its predecessor, the Tax Equity and Fiscal Responsibility Act of 1982. The study then compares the tax liability under these tax codes with a nondistortionary tax scheme. Results indicate that the Tax Reform Act of 1986 reduced the distortionary effects of the tax code on capital investment decisions. However, a large portion of the reduction can be attributed to the change in the average tax rate.
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Bogaevskaya, O. V. « Corporate Tax Reform in the USA ». International Trade and Trade Policy, no 3 (8 octobre 2019) : 44–56. http://dx.doi.org/10.21686/2410-7395-2019-3-44-56.

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The article examines the prerequisites, content and effects of changes in the corporate taxation system adopted in the United States under the Tax Cuts and Jobs Act in December 2017. The critical flaws and limitations of the US corporate taxation system that existed until 2018 are analyzed in detail. A conceptual consensus on the need to reduce the corporate tax rate and solving the problem of profit shifting existed in the US expert community for some time before the election of President D. Trump, but the balance of power in Congress made the changes impossible. The key provisions of the new corporate tax system, which primarily include a reduction in the corporate tax rate, reforming companies’ international taxation and measures to stimulate investment in the United States, are outlined. The expected consequences and first results of the reform, the impact of the adopted changes on the activities of different types of companies and on the US economy are considered. It is shown that the reform will lead to increased activity of both American and foreign companies on the US territory, as well as, possibly, a decrease in corporate tax rates in other countries. It is concluded that, despite the considerable budget burden, the tax reform will contribute to economic growth in the United States, both in the short and long run.
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Barker, Joel. « Corporate Inversions : The Migration Of Corporate Tax Revenue ». Journal of Applied Business Research (JABR) 32, no 4 (30 juin 2016) : 1137–44. http://dx.doi.org/10.19030/jabr.v32i4.9726.

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Estimates of over 20 billion of tax revenue are lost to our economy because of corporate inversions. Therefore, lawmakers are actively exploring ways to stop the hemorrhaging of corporate tax-revenues, tighten restrictions on corporate inversions, and to find ways to collect on defer tax revenues. From a business prospective, corporate inversions are nothing less than prudent, innovative, business strategies to enhance corporate profits. However, it’s undoubtedly having a significant impact on U.S. tax revenues and ultimately reducing domestic investments. Ireland is now the most popular new home to many U.S. Corporations, especially within the pharmaceutical industry. The advantageous tax incentives offered by Ireland is a “no-brainer,” when compared to the heavy taxes levied upon domestic business. Since the Tax Reform Act of 1986, there has been no major tax reform to the United States Tax System. Despite the various proposals and recommendations made to address this growing economic issue, all concern parties are in consensus that the United States Tax System needs reform.
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Bazel, Philip, et Jack Mintz. « Policy Forum : Is Accelerated Depreciation Good or Misguided Tax Policy ? » Canadian Tax Journal/Revue fiscale canadienne 67, no 1 (avril 2019) : 41–55. http://dx.doi.org/10.32721/ctj.2019.67.1.pf.bazel.

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The authors examine the implications of Canada's response to the 2017 US tax reform. Canada's focus on accelerated tax depreciation will achieve lower marginal effective tax rates on capital for taxpaying companies, well below the US levels achieved with the Tax Cuts and Jobs Act that came into effect on January 1, 2018. By ignoring neutrality, the government offsets some of the potential gains by reducing the tax burden on capital, thereby failing to maximize efficiency gains from a better corporate tax system. Further, Canada's approach fails to respond to competitiveness effects of US reforms on corporate tax base erosion in Canada as companies shift profits to the United States. The low US tax rate on intangible income will draw certain functions to the United States. A more comprehensive approach to corporate tax reform, including some reduction in corporate income tax rates, would have been a preferable response.
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Slemrod, Joel. « Is This Tax Reform, or Just Confusion ? » Journal of Economic Perspectives 32, no 4 (1 novembre 2018) : 73–96. http://dx.doi.org/10.1257/jep.32.4.73.

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Based on the experience of recent decades, the United States apparently musters the political will to change its tax system comprehensively about every 30 years, so it seems especially important to get it right when the chance arises. Based on the strong public statements of economists opposing and supporting the Tax Cuts and Jobs Act of 2017, a causal observer might wonder whether this law was tax reform or mere confusion. In this paper, I address that question and, more importantly, offer an assessment of the Tax Cuts and Jobs Act. The law is clearly not “tax reform” as economists usually use that term: that is, it does not seek to broaden the tax base and reduce marginal rates in a roughly revenue-neutral manner. However, the law is not just a muddle. It seeks to address some widely acknowledged issues with corporate taxation, and takes some steps toward broadening the tax base, in part by reducing the incentive to itemize deductions.
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Auerbach, Alan J. « The Tax Reform Act of 1986 and the Cost of Capital ». Journal of Economic Perspectives 1, no 1 (1 août 1987) : 73–86. http://dx.doi.org/10.1257/jep.1.1.73.

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The broad outlines of the recently passed Tax Reform Act of 1986 suggest a shift in the tax burden toward business. Over the five-year period 1987-1991, corporate tax revenues are projected to increase by $120.3 billion with individual tax revenues declining by $121.9 billion. It is natural to conclude that business investment in plant and equipment will be discouraged by this shift. Yet the relationship between tax revenues and investment incentives is a complicated one, particularly when the change in business tax revenues is accompanied by a major change in the tax structure producing these revenues. This paper's primary aim is to discuss the channels through which this major change in the tax structure will affect the incentives for business investment. Among the related questions discussed are the law's impact on the efficiency of capital allocation; corporate debt-equity ratios; corporate mergers and takeovers; tax shelter activity and the nonpayment of taxes by individuals and corporations; the strength of foreign investment in the United States; and the market value of the equity shares of U.S. corporations.
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Thèses sur le sujet "Tax Reform Act of 1969 (United States)"

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Siddiqi, Mazhar Ali. « Dividend capture and the Tax Reform Act of 1986 / ». Thesis, Connect to this title online ; UW restricted, 1991. http://hdl.handle.net/1773/8775.

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Samelson, Donald. « An empirical investigation of economic consequences of the Tax Reform Act of 1986 ». Diss., This resource online, 1992. http://scholar.lib.vt.edu/theses/available/etd-06062008-165448/.

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Finley, Janene R. « An empirical study of the effect of the change in the burden of proof in the Internal Revenue Service Restructuring and Reform Act of 1998 on the United States Tax Court / ». Available to subscribers only, 2007. http://proquest.umi.com/pqdweb?did=1362513441&sid=5&Fmt=2&clientId=1509&RQT=309&VName=PQD.

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Kienker, Brittany Lynn. « The Henry Ford : sustaining Henry Ford's philanthropic legacy ». Thesis, 2014. http://hdl.handle.net/1805/4654.

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Indiana University-Purdue University Indianapolis (IUPUI)
This dissertation argues that the Edison Institute (presently known as The Henry Ford in Dearborn, Michigan) survived internal and external challenges through the evolution of the Ford family’s leadership and the organization’s funding strategy. Following Henry Ford’s death, the museum complex relied upon the Ford Foundation and the Ford Motor Company Fund as its sole means of philanthropic support. These foundations granted the Edison Institute a significant endowment, which it used to sustain its facilities in conjunction with its inaugural fundraising program. Navigating a changing legal, corporate, and philanthropic landscape in Detroit and around the world, the Ford family perpetuated Henry Ford’s legacy at the Edison Institute with the valuable guidance of executives and staff of their corporation, foundation, and philanthropies. Together they transitioned the Edison Institute into a sustainable and public nonprofit organization by overcoming threats related to the deaths of two generations of the Ford family, changes in the Edison Institute’s administration and organizational structure, the reorganization of the Ford Foundation, the effects of the Tax Reform Act of 1969, and legal complications due to overlap between the Fords’ corporate and philanthropic interests. The Ford family provided integral leadership for the development and evolution of the Edison Institute’s funding strategy and its relationship to their other corporate and philanthropic enterprises. The Institute’s management and funding can be best understood within the context of philanthropic developments of the Ford family during this period, including the formation of the Ford Foundation’s funding and concurrent activity.   This dissertation focuses on the research question of how the Edison Institute survived the Ford family’s evolving philanthropic strategy to seek a sustainable funding and management structure. The work examines its central research question over multiple chapters organized around the Ford family’s changing leadership at the Edison Institute, the increase of professionalized managers, and the Ford’s use of their corporation and philanthropies to provide integral support to the Edison Institute. In order to sustain the Edison Institute throughout the twentieth century, it adapted its operations to accommodate Henry Ford’s founding legacy, its legal environment, and the evolving practice of philanthropy in the United States.
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Livres sur le sujet "Tax Reform Act of 1969 (United States)"

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Taxation, United States Congress Joint Committee on. Report of the Joint Committee on Taxation relating to the Internal Revenue Service as required by the IRS Reform and Restructuring Act of 1998 : Prepared for the House Committees on Ways and Means, Appropriations, and Government Reform and the Senate Committees on Finance, Appropriations, and Governmental Affairs for a joint review scheduled on May 25, 1999. [Washington, D.C : Joint Committee on Taxation, 1999.

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United States. Congress. Joint Committee on Taxation. Report of the Joint Committee on Taxation relating to the Internal Revenue Service as required by the IRS Reform and Restructuring Act of 1998 : Prepared for the House Committees on Ways and Means, Appropriations, and Government Reform and the Senate Committees on Finance, Appropriations, and Governmental Affairs for a joint review scheduled on May 25, 1999. [Washington, D.C : Joint Committee on Taxation, 1999.

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United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight. Implementation of the Internal Revenue Service Restructuring and Reform Act : Hearing before the Subcommittee on Oversight of the Committee on Ways and Means, House of Representatives, One Hundred Sixth Congress, first session, July 22, 1999. Washington : U.S. G.P.O., 2001.

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Samwick, Andrew. Tax shelters and passive losses after the Tax Reform Act of 1986. Cambridge, MA : National Bureau of Economic Research, 1995.

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Nelson, A. Gene. Understanding the Tax Reform Act of 1986. Corvallis, Or : Extension Service, Oregon State University, 1986.

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Diana, Day, Peterson Douglas D et Ledebur Larry C, dir. Your cityʼs 1040 : Federal tax reform and municipalities. Washington, D.C : National League of Cities, 1987.

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David, Brumbaugh, et Library of Congress. Major Issues System, dir. Tax Reform Act of 1986 (P.L. 99-514). [Washington, D.C.] : Congressional Research Service, Library of Congress, Major Issues System, 1987.

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David, Brumbaugh, et Library of Congress. Major Issues System, dir. Tax Reform Act of 1986 (P.L. 99-514). [Washington, D.C.] : Congressional Research Service, Library of Congress, Major Issues System, 1987.

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Montana. Legislature. Revenue Oversight Committee. et Peat, Marwick, Mitchell & Co. Policy Economics Group., dir. Impact of the Tax Reform Act of 1986 on Montana residents. [S.l.] : The Group, 1987.

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David, Brumbaugh, et Library of Congress. Major Issues System, dir. Tax Reform Act of 1986 (P.L. 99-514) : Proposed changes. [Washington, D.C.] : Library of Congress, Congressional Research Service, Major Issues System, 1987.

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Chapitres de livres sur le sujet "Tax Reform Act of 1969 (United States)"

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Henderson, Yolanda K. « Applications of General Equilibrium Models to the 1986 Tax Reform Act in The United States ». Dans Applied General Equilibrium Modelling, 7–28. Dordrecht : Springer Netherlands, 1991. http://dx.doi.org/10.1007/978-94-015-7908-7_2.

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Faulkenbury, Evan. « Introduction ». Dans Poll Power, 1–7. University of North Carolina Press, 2019. http://dx.doi.org/10.5149/northcarolina/9781469652009.003.0001.

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This introduction lays out the main arguments of the book. It begins with a case study, a voting rights campaign in Orangeburg, South Carolina, during the early 1960s with support from the Voter Education Project (VEP). It then zooms out and explains the scope and importance of the VEP during the civil rights era. The book argues that the VEP was the main engine that drove the civil rights movement forward by providing money and support to hundreds of African American grassroots campaigns throughout eleven southern states, money deriving from philanthropic foundations, up until conservatives cut off the money supply through the Tax Reform Act of 1969.
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Verdier, Pierre-Hugues. « “Geneva Is Beautiful This Time of Year” ». Dans Global Banks on Trial, 75–108. Oxford University Press, 2020. http://dx.doi.org/10.1093/oso/9780190675776.003.0003.

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This chapter examines the U.S. enforcement campaign against Swiss banks that facilitated tax evasion by U.S. customers and its impact on the global regime for tax information sharing. After reviewing the legal and policy issues raised by offshore tax evasion, the chapter examines how the U.S. criminal prosecution of UBS led to the release of tens of thousands of U.S. customer names to the IRS, opening an unprecedented breach in Swiss bank secrecy. The UBS case opened the way for prosecutions of other Swiss banks; negotiations with Switzerland on tax disclosure; and U.S. adoption of the Foreign Account Tax Compliance Act (FATCA), which penalizes foreign banks that fail to disclose U.S. customer accounts. While the U.S. approach initially encountered significant resistance, many countries, including major offshore centers, concluded bilateral information-sharing agreements with the United States, while some onshore jurisdictions adopted FATCA-like legislation to fight offshore tax evasion. Eventually, the U.S. approach provided a model for multilateral reform through the OECD’s Common Reporting Standard (CRS), which provides automatic exchange of account information among numerous jurisdictions.
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Hershkoff, Helen, et Stephen Loffredo. « Health ». Dans Getting By, 329–428. Oxford University Press, 2019. http://dx.doi.org/10.1093/oso/9780190080860.003.0004.

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This chapter addresses the issue of health care for low-income people. The United States, virtually alone among developed nations, does not offer universal access to health care, leaving many millions of individuals without health insurance or other means of obtaining necessary medical services. In 2010, Congress enacted the landmark Patient Protection and Affordable Care Act (ACA)—popularly known as “Obamacare”—marking an important but incomplete response to the nation’s health care crisis. This chapter examines the ACA in detail, including its impact on Medicaid and Medicare, the major government health programs in the United States, its creation of Health Insurance Exchanges and tax credits to help low-income households obtain private health coverage, and the reform of private health insurance markets through a patient’s bill of rights, which, among other measures, prohibits insurance companies from refusing coverage for preexisting medical conditions. Perhaps the most critical aspect of the ACA was its expansion of Medicaid to cover virtually all low-income citizens (and certain immigrants) who do not qualify for other health coverage. Although several states opted out of the ACA’s Medicaid expansion, the Medicaid program nevertheless remains the largest single provider of health coverage in the United States. This chapter also provides a detailed description of Medicaid, its eligibility criteria and scope of coverage; the Child Health Insurance Program (CHIP), a government-funded health insurance program for children in households with too much income to qualify for Medicaid; and Medicare, the federal health insurance program for aged, blind, and disabled individuals.
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Rapports d'organisations sur le sujet "Tax Reform Act of 1969 (United States)"

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Slemrod, Joel. The Impact of the Tax Reform Act of 1986 on Foreign Direct Investment to and from the United States. Cambridge, MA : National Bureau of Economic Research, janvier 1990. http://dx.doi.org/10.3386/w3234.

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Lazonick, William. Investing in Innovation : A Policy Framework for Attaining Sustainable Prosperity in the United States. Institute for New Economic Thinking Working Paper Series, mars 2022. http://dx.doi.org/10.36687/inetwp182.

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“Sustainable prosperity” denotes an economy that generates stable and equitable growth for a large and growing middle class. From the 1940s into the 1970s, the United States appeared to be on a trajectory of sustainable prosperity, especially for white-male members of the U.S. labor force. Since the 1980s, however, an increasing proportion of the U.S labor force has experienced unstable employment and inequitable income, while growing numbers of the business firms upon which they rely for employment have generated anemic productivity growth. Stable and equitable growth requires innovative enterprise. The essence of innovative enterprise is investment in productive capabilities that can generate higher-quality, lower-cost goods and services than those previously available. The innovative enterprise tends to be a business firm—a unit of strategic control that, by selling products, must make profits over time to survive. In a modern society, however, business firms are not alone in making investments in the productive capabilities required to generate innovative goods and services. Household units and government agencies also make investments in productive capabilities upon which business firms rely for their own investment activities. When they work in a harmonious fashion, these three types of organizations—household units, government agencies, and business firms—constitute “the investment triad.” The Biden administration’s Build Back Better agenda to restore sustainable prosperity in the United States focuses on investment in productive capabilities by two of the three types of organizations in the triad: government agencies, implementing the Infrastructure Investment and Jobs Act, and household units, implementing the yet-to-be-passed American Families Act. Absent, however, is a policy agenda to encourage and enable investment in innovation by business firms. This gaping lacuna is particularly problematic because many of the largest industrial corporations in the United States place a far higher priority on distributing the contents of the corporate treasury to shareholders in the form of cash dividends and stock buybacks for the sake of higher stock yields than on investing in the productive capabilities of their workforces for the sake of innovation. Based on analyzes of the “financialization” of major U.S. business corporations, I argue that, unless Build Back Better includes an effective policy agenda to encourage and enable corporate investment in innovation, the Biden administration’s program for attaining stable and equitable growth will fail. Drawing on the experience of the U.S. economy over the past seven decades, I summarize how the United States moved toward stable and equitable growth from the late 1940s through the 1970s under a “retain-and-reinvest” resource-allocation regime at major U.S. business firms. Companies retained a substantial portion of their profits to reinvest in productive capabilities, including those of career employees. In contrast, since the early 1980s, under a “downsize-and-distribute” corporate resource-allocation regime, unstable employment, inequitable income, and sagging productivity have characterized the U.S. economy. In transition from retain-and-reinvest to downsize-and-distribute, many of the largest, most powerful corporations have adopted a “dominate-and-distribute” resource-allocation regime: Based on the innovative capabilities that they have previously developed, these companies dominate market segments of their industries but prioritize shareholders in corporate resource allocation. The practice of open-market share repurchases—aka stock buybacks—at major U.S. business corporations has been central to the dominate-and-distribute and downsize-and-distribute regimes. Since the mid-1980s, stock buybacks have become the prime mode for the legalized looting of the business corporation. I call this looting process “predatory value extraction” and contend that it is the fundamental cause of the increasing concentration of income among the richest household units and the erosion of middle-class employment opportunities for most other Americans. I conclude the paper by outlining a policy framework that could stop the looting of the business corporation and put in place social institutions that support sustainable prosperity. The agenda includes a ban on stock buybacks done as open-market repurchases, radical changes in incentives for senior corporate executives, representation of workers and taxpayers as directors on corporate boards, reform of the tax system to reward innovation and penalize financialization, and, guided by the investment-triad framework, government programs to support “collective and cumulative careers” of members of the U.S. labor force. Sustained investment in human capabilities by the investment triad, including business firms, would make it possible for an ever-increasing portion of the U.S. labor force to engage in the productive careers that underpin upward socioeconomic mobility, which would be manifested by a growing, robust, and hopeful American middle class.
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Kahima, Samuel, Solomon Rukundo et Victor Phillip Makmot. Tax Certainty ? The Private Rulings Regime in Uganda in Comparative Perspective. Institute of Development Studies, janvier 2021. http://dx.doi.org/10.19088/ictd.2021.001.

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Taxpayers sometimes engage in complex transactions with uncertain tax treatment, such as mergers, acquisitions, demergers and spin-offs. With the rise of global value chains and proliferation of multinational corporations, these transactions increasingly involve transnational financial arrangements and cross-border dealings, making tax treatment even more uncertain. If improperly structured, such transactions could have costly tax consequences. One approach to dealing with this uncertainty is to create a private rulings regime, whereby a taxpayer applies for a private ruling by submitting a statement detailing the transaction (proposed or completed) to the tax authority. The tax authority interprets and applies the tax laws to the requesting taxpayer’s specific set of facts in a written private ruling. The private ruling offers taxpayers certainty as to how the tax authority views the transaction, and the tax treatment the taxpayer can expect based on the specific facts presented. Private rulings are a common feature of many tax systems around the world, and their main goal is to promote tax certainty and increase investor confidence in the tax system. This is especially important in a developing country like Uganda, whose tax laws are often amended and may not anticipate emerging transnational tax issues. Private rulings in Uganda may be applied for in writing prior to or after engaging in the transaction. The Tax Procedures Code Act (TPCA), which provides for private rulings, requires applicants to make a full and true disclosure of the transaction before a private ruling may be issued. This paper evaluates the Ugandan private rulings regime, offering a comparative perspective by highlighting similarities and contrasts between the Ugandan regime and that of other jurisdictions, including the United States, Australia, South Africa and Kenya. The Ugandan private rulings regime has a number of strengths. It is not just an administrative measure as in some jurisdictions, but is based on statute. Rulings are issued from a central office – instead of different district offices, which may result in conflicting rulings. Rather than an elaborate appeals process, the private ruling is only binding on the URA and not on the taxpayer, so a dissatisfied taxpayer can simply ignore the ruling. The URA team that handles private rulings has diverse professional backgrounds, which allows for a better understanding of applications. There are, however, a number of limitations of the Ugandan private rulings system. The procedure of revocation of a private ruling is uncertain. Private rulings are not published, which makes them a form of ‘secret law’. There is no fee for private rulings, which contributes to a delay in the process of issuing one. There is understaffing in the unit that handles private rulings. Finally, there remains a very high risk of bias against the taxpayer because the unit is answerable to a Commissioner whose chief mandate is collection of revenue. A reform of the private rulings regime is therefore necessary, and this would include clarifying the circumstances under which revocation may occur, introducing an application fee, increasing the staffing of the unit responsible, and placing the unit under a Commissioner who does not have a collection mandate. While the private rulings regime in Uganda has shortcomings, it remains an essential tool in supporting investor confidence in the tax regime.
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