US income taxation of new financial products

• 成果类型: Article; Proceedings Paper
• 署名作者: Warren, AC Jr
• 署名单位: Harvard University
• 刊物名称: JOURNAL OF PUBLIC ECONOMICS
• ISSN/ISSBN: 0047-2727
• DOI: 10.1016/S0047-2727(03)00042-2
• 发表日期: 2004
• 页码: 899-923
• 关键词: derivatives; options; corporate tax; financial innovation

摘要

This paper discusses the response of the US federal income tax to financial innovation. Income taxation in the US and elsewhere has traditionally relied on distinctions, such as the difference between fixed and contingent returns, that can be undermined by new financial products. The principal tax law responses to innovative products have been: (1) transactional analysis, which aggregates or disaggregates new transactions to conform them to existing legal categories, (2) taxation of changes in market value, rather than realization events, (3) taxation based on an assumed formula, and (4) anti-avoidance administrative approaches. (C) 2003 Elsevier B.V. All rights reserved.