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The Taxation of Treasury Inflation Protected Securities: Are They Tax-Disadvantaged?
No full textInflation is back, causing problems for taxpayers looking for safe, inflation-protected investments. This Article engages in an in-depth analysis of an understudied part of the Internal Revenue Code and associated Treasury Regulations section 1.1275-7, the inflation-indexed debt rules, asking whether Treasury Inflation Protected Securities (TIPS) can act as a suitable hedge against inflation for taxable investors. TIPS are often considered tax-disadvantaged instruments, and this Article questions the extent to which that is true. I examine TIPS relative to inflation, nominal Treasuries and I Bonds, and in doing so make three important contributions to tax scholarship. First, I present original empirical analysis on financial data from the 2003-22 period, finding that TIPS are taxed at least as favorably as nominal Treasuries on a buy-and-hold basis. Under certain assumptions, like interest withholding, the section 1.1275-7 regime imposes less onerous tax consequences on TIPS than on nominals. Second, my results confirm that the performance of TIPS relative to nominal Treasuries depends on how unanticipated inflation deviates from expected inflation. Analysis of the 2003-21 period shows that nominals outperformed TIPS on both a pre-and a post-tax basis, while analysis of the 2003-22 period shows that 10-year TIPS issued between 2012 and 2022 generally outperformed nominals precisely because of the rise in unanticipated inflation in 2021 caused by the response to COVID-19. Third, I find that since 2011 all riskless bonds have generally had negative real yields on an after-tax basis. These findings have important implications for current tax policy since they show that taxpayers cannot access positive real riskless returns on an after-tax basis. With the world in a period of rising interest rates and high inflation, this suggests that it may be time to reconsider the canonical emphasis on nominal rather than real taxation
Safe Harbor Regimen in Transfer Pricing—An African Perspective
No full textThe transfer pricing methods established by the transfer pricing rules and practices of many countries (generally modelled after the OECD Transfer Pricing Guidelines) are not only complex to implement, but also fraught with challenges such as the lack of availability of comparables for benchmarking purposes, low accessibility of databases and the failed capacity of tax authorities to implement them. For tax authorities in African countries, these challenges are further amplified, for example, by lack of resources, especially human and capital, and a shortage of experience in applying transfer pricing rules. As a result of these challenges, achieving arm’s length prices for transactions between related entities has posed a significant burden and cost to both taxpayers and tax authorities. The OECD and the G20 initiated the Base Erosion and Profit Shifting (BEPS) project to ameliorate some of the challenges listed above and to address the erosion of tax bases and shifting of profit to low-tax jurisdictions—challenges ultimately tied to the limitations of the arm’s-length standard and application of transfer pricing methodologies.
However, tax authorities in some jurisdictions already apply safe harbors and other simplified measures to mitigate the challenges of applying transfer pricing rules and practices. These measures reduce the need for taxpayers to prepare detailed transfer pricing documentation in justifying the arm’s-length price fixed for goods and services transferred among related entities. They also remove the need for tax authorities to audit the books of taxpayers where they act within approved margins. In some cases, they exempt taxpayers from applying transfer pricing rules to related-party transactions. Historically, the OECD discouraged the use of safe harbors by tax jurisdictions, claiming that they conflict with the arm’s length standard. In recent times, the OECD has changed its views on the use of safe harbors. The Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy recommends the use of safe harbors, including those in the GloBE rules, in determining marketing and distribution profits.
Given the positive recommendation by the OECD on the use of safe harbors in recent times, this Article analyzes the adoption and application of safe harbor regimes by certain countries and discusses how they should be designed. It recommends the cautious adoption and application of safe harbor regimes by tax authorities in African countries to achieve increased revenue collection, tax efficiency, certainty, simplicity and convenience, and to circumvent the complicated comparability analysis
Mysticism, Hybridity, and Intersectionality in the Lives and Works of Inés Estéban, Isabel de la Cruz, and St. Teresa of Ávila
No full textSpain is frequently said to have come late to Christian mysticism. While mysticism had gained popularity in Europe beginning in the early twelfth century, Christian mysticism in Spain did not gain a real toehold until the fifteenth and sixteenth centuries. Unlike mystics in most other European countries, mystics in Spain were, more often than not, of converso heritage and were frequently women. As a result, they were closely scrutinized by the Spanish Inquisition. This paper examines three Spanish women mystics—Inés Estéban, Isabel de la Cruz, and Teresa de Ávila—all of whom had some degree of inter-action with the Holy Office of the Inquisition, two of whom were convicted of crimes against Christianity, and one who became the first female Doctor of the Church. An examination of the lives and inquisitorial interactions of these women through the lenses of intersectionality and hybridity allow us to see that these mystical conversas used a variety of hybrid strategies to make a place for themselves within the larger society of sixteenth-century Spain, and to attempt to integrate themselves into society’s power structures
Introducing a Commentary: A Translation of the Introductory Verses to Illumination on Sense and Meaning in the Bhāgavata Purāṇa by Shridhara Swami (c.1400 ad)
No full textThe Bhāgavata Purāṇa (c.900- 1000 ad) is a well-known Sanskrit text consisting of twelve books, divided into just over three-hundred and thirty chapters, and covering ancient myth and dynastic history, as well as an analysis of various philosophies, theologies, and cosmologies to support the argument that Krishna is the supreme deity over and above other deities in the Hindu pantheon like Vishnu and Rāma. The first known manuscript is dated at 112 4 – 1125 ad, the earliest known references to it are from Vopadeva (c.1300 ad) and Madhva (c.1238-1317), and it remains an important scripture in con-temporary Hinduism
Introduction to the Special Issue: Patriotism, Public Opinion, and National Defense in Estonia, Finland, and Sweden
No full textHow do political communities stick together as polities in times of crisis? What is needed to motivate their citizens work together to deter threats, maintain state monopolies of violence, and sustain different forms of military alliances and cooperation? The answer, in large part, is patriotism. Patriotic thinking—both as a sentiment and as an element of political ideology—is a central tenet in building states and conducting state affairs. From the perspective of political philosophy, patriotism is often characterized as love for one’s country and as an affective relationship imbued with such emotions as pride, honor, and appreciation for the collective that it represents. Scholars from the tradition of republican patriotism argue that such love may be directed toward political institutions and that it helps form a way of life that sustains the liberty of a state’s population. This stands in contrast to nationalism, which regards thesame object of veneration, the homeland, with less tolerance of heterogeneity and political disunion. Both patriotism and nationalism are conceptualized in a variety of ways and can take on meanings as varied as benign civic unity and exclusionary chauvinism. Patriotism is often conceptualized as a form of civic virtue, stressing the way it prioritizes the community ahead of the individual
The Legitimacy of Conscription in Democracy: Connections between Conscription Politics and Public Opinion in Parliamentary Debates in Finland and Sweden in the 2010s
No full textConscription is a political institution that may socialize individuals to acquire such values as a sense of patriotism and duty toward state. In democratic countries, public support for conscription is vital. In this article we study the effects of public opinion on Swedish and Finnish politics from 2008 to 2010 and from 2017 to 2021. Based on an analysis of political language, we argue that the use of such language is central to seeking legitimacy for controversial issues. To that end, political discussions and interpretations of public opinion are central ways of creating and legitimizing policy. By conducting a qualitative, conceptual, and contextual analysis of digitized parliamentary documents in Sweden and Finland, this article suggests that in both countries political elites have spoken about public opinion to support the crafting of defense policy, particularly when speaking about the necessity to reform conscription so as to maintain citizens’ engagement with defense and their acceptance of conscription as a core institution of national defense
Book Review: Iranian Proxy Groups in Iraq, Syria, and Yemen: A Principal-Agent Comparative Analysis
No full textReview of: Zorri, Dianne, Houman Sadri, and David Ellis, Iranian Proxy Groups in Iraq, Syria, and Yemen: A Principal-Agent Comparative Analysis. Tampa, FL: JSOU Press, 2021
An Investigation of Identity and Ontology at Salango, Ecuador (BCE 100–300 CE): Combining Paleopathological, Mortuary, and Stable Isotopic Analyses
No full textBioarchaeologists have increasingly investigated social identities of past peoples, engaging with theory from a variety of sources, including Indigenous perspectives. In this article, we discuss and compare successive Very Early Guangala (100 BCE–CE 1) and succeeding Early Guangala (CE 1–300) phase burials located near the north perimeter of Salango, a shoreline site and ritual sanctuary serving multiple communities of the central coast of Ecuador. Very Early Guangala burials in low mounds included many infants, accompanied by stone figurines and marine shells, who demonstrated skeletal lesions of pronounced and chronic stress. Early Guangala burials were located in the same area but without funerary architecture. These later burials were predominantly adult at the time of death, endowed with a different set of goods, and displayed distinct frequencies of pathological conditions (possibly related to demographic differences). Isotopic evidence of diet and migration show that throughout both periods, connection to the ocean through foodways was common, despite the possibility of some individuals migrating to or from the area. Drawing on theory about relational identities and community, we interpret these paleopathological, mortuary, and isotopic trends to demonstrate that in particular contexts, humans and objects were seen as interchangeable and that a lifelong connection to the ocean was at the core of community at Salango.
Los bioarqueólogos han investigado las identidades de la gente en el pasado, utilizando una variedad de teorías, inclusivo de las perspectivas indígenas. En este artículo, discutimos y comparamos entierros de la fase Guangala Muy Temprana (100 a. C.–1 d. C.) y Guangala Temprana (1–300 d. C.) ubicados cerca del perímetro norte de Salango, un sitio costero y santuario ritual que sirve a múltiples comunidades de la costa central del Ecuador. La mayoridad de los entierros de la fase Guangala Muy Temprana fueron infantes y acompañados por figurillas de piedra y conchas marinas. Fueron enterrados en dos montículos construido con distintas capas de arena y arcilla. Los entierros de la fase Guangala Temprana fueron cerca el mismo lugar, pero afuera de los montículos y con otros tipos de artefactos. La mayoridad de los entierros de esta fase fueron adultos. La evidencia isotópica de la dieta y la migración muestra que a lo largo de ambos períodos la conexión con el océano fue común. Con la teoría de identidades relacionales y comunidad, interpretamos estos patrones de paleopatología, practicas funerarios, y isotopos para demostrar, en contextos particulares, los humanos y los objetos se consideraban intercámbiales. También, discutimos que la conexión a la mar estaba el núcleo de la comunidad de Salango
Heavenly Meals and Humble Hearts: Foodways in a Jesuit Context in Spanish Colonial New Granada and Early Republican Colombia
No full textThis research explores how bone isotopic data (δ13C, δ15N), in combination with analyses of dental pathology, dental calculus, and archival research, can illustrate relationships between food, colonization, social identities, and the norms of religious life in Colonial and Republican Bogotá, Colombia. We analyze skeletal remains from the San Ignacio Jesuit Church, an important colonial landmark that has served as a space of sacred burial for 400 years. Through our multidisciplinary approach to variables such as social status and membership in a religious order, we show how the colonization of bodies and minds transformed the way that people mobilized food as a symbol of social identity, often in unexpected ways. For example, Jesuit priests consumed significant amounts of meat in their diets, which contravenes notions of piety and vows of poverty typical of their congregation. Similarly, there are varying levels of diversity in the plants being consumed among different segments of the local population, suggesting deliberate choices around the inclusion of native or foreign species in people’s diets. In the early Republican period (nineteenth century), we see a difference in food choices among local elites, along with the adoption of new oral hygiene practices, as embodying new cultural notions of modernity.Esta investigación explora cómo los datos isotópicos (δ13C y δ15N) extraídos de restos óseos humanos pueden interpretarse a la luz de otras categorías de evidencia histórica y bioarqueológica para aclarar las relaciones existentes entre alimentación, colonización, identidades sociales y normas de la vida religiosa durante los periodos colonial y republicano en Bogotá, Colombia. Analizamos restos óseos de la iglesia jesuita de San Ignacio, un destacado monumento del centro histórico de Bogotá que ha sido usado como espacio funerario desde mediados del siglo XVII. A través de un enfoque multidisciplinario que tiene en cuenta variables como el estatus social y la pertenencia a una orden religiosa particular, mostramos cómo la colonización de cuerpos y mentes transformó la forma en que ciertos habitantes de la Santafé colonial utilizaron los alimentos como expresiones de identidad social. Por ejemplo, los sacerdotes jesuitas inhumados en San Ignacio parecen haber incluido cantidades importantes de carne en sus dietas, lo cual contradice las nociones de piedad y los votos de pobreza característicos de su congregación. De manera similar, en épocas coloniales, ciertos alimentos de origen vegetal se distribuyeron de forma distinta entre los diferentes segmentos de la población local, lo que sugiere que sus dietas estuvieron atravesadas por elecciones deliberadas en torno a la inclusión de plantas endógenas o exógenas. A principios del período republicano (siglo XIX), observamos una diferencia en las opciones alimentarias preferidas entre las élites locales, junto con la adopción de nuevas prácticas de higiene oral, que reflejan en ellas una encarnación de nociones culturales emergentes propias de la modernidad
Fostering Fortitude: Patriotism and Resilience as Civic Piety in Textbooks of National Defense Courses in Finland, 1967–2018
No full textThis article analyzes “National Defense Courses” textbooks that were used to disseminate defense information to the political, social, and administrative elite in Finland. Textbooks from 1967 to 2018 provide qualitative historicaland sociological data, showing how Finland has prepared for war and other security contingencies for the past five decades. The main shift in fostering the population’s allegiance to the state has gone from addressing the management of political heterodoxy as a patriotic endeavor to one of cultivating apolitical resilience in the face of adversity. Both patriotism and resilience appear in the texts as forms of civic piety, in which people’s individual preferences give way to collective interests