Showing papers on "Apportionment published in 2006"

Corporate Income Taxation of Multinationals and Unemployment

Abstract: Within a two-country model with involuntary unemployment, this paper investigates corporate income taxation under separate accounting versus formula apportionment. In contrast to separate accounting, under formula apportionment the corporate tax policy causes a fiscal externality which goes back to unemployment. This unemployment externality is lowest when the apportionment formula does not contain a payroll factor. It tends to compensate other externalities such that tax rates become inefficiently low. In an empirical calibration, we show that the transition from separate accounting to formula apportionment improves welfare and reduces unemployment. The welfare increase is strongest under a pure sales formula.

Company-tax coordination cum tax-rate competition in the European union

Abstract: This paper reviews the recent theoretical literature that analyses the European Union's policy to eliminate preferential corporate tax regimes and the proposal to introduce a consolidated EU tax base with formula apportionment for the taxation of multinational firms. Since neither proposal includes a harmonisation of corporate tax rates, a core issue is how tax competition between member states will be affected by these partial coordination measures. The conclusions from our review are supportive of the EU's ban on preferential tax regimes, but the economic incentive effects of a switch to formula apportionment are found to be ambiguous.

Mathematics and democracy : recent advances in voting systems and collective choice

Abstract: Power Indices Taking into Account Agents' Preferences.- The Sunfish Against the Octopus: Opposing Compactness to Gerrymandering.- Apportionment: Uni- and Bi-Dimensional.- Minimum Total Deviation Apportionments.- Comparison of Electoral Systems: Simulative and Game Theoretic Approaches.- How to Elect a Representative Committee Using Approval Balloting.- On Some Distance Aspects in Social Choice Theory.- Algorithms for Biproportional Apportionment.- Distance from Consensus: A Theme and Variations.- A Strategic Problem in Approval Voting.- The Italian Bug: A Flawed Procedure for Bi-Proportional Seat Allocation.- Current Issues of Apportionment Methods.- A Gentle Majority Clause for the Apportionment of Committee Seats.- Allotment According to Preferential Vote: Ecuador's Elections.- Degressively Proportional Methods for the Allotment of the European Parliament Seats Amongst the EU Member States.- Hidden Mathematical Structures of Voting.- A Comparison of Electoral Formulae for the Faroese Parliament.

Minimum Total Deviation Apportionments

Abstract: This note presents an algorithm for computing the minimum total deviation apportionment. Some properties of this apportionment are also explored. This particular apportionment arises from the jurisprudential concern that total deviation is the appropriate measure for the harm caused by malapportionment of the United States House of Representatives.

Senate Apportionment as a Source of Political Inequality

Abstract: Political scientists have long known that the equal representation of states in the U.S. Senate and the placement of state lines might disadvantage politically relevant groups, granting some citizens greater voting weight in the chamber. Yet we lack systematic, longitudinal evidence that identifies the groups disadvantaged by Senate malapportionment, the sources of this disadvantage, and probes the policy consequences. In this article, I compare each state's liberalism and racial composition with its relative voting weight in the Senate over time. Additionally, I examine whether roll-call coalitions in the Senate map onto these patterns of state ideology and racial composition.

Current Issues of Apportionment Methods

Abstract: Three apportionment problems are addressed that are of current interest in Germany and Switzerland: the assignment of committee seats in a way that preserves the parliamentary majority-minority relation, the introduction of minimum restrictions in a two-ballot system to accomodate the direct seats won by the constituency ballots, and biproportional apportionment methods for systems with multiple districts so as to achieve proportionality between party votes as well as between district populations.

The Delineation and Apportionment of an EU Consolidated Tax Base for Multi-jurisdictional Corporate Income Taxation: a Review of Issues and Options

Abstract: The Commission Services study on Company Taxation in the Internal Market and the Communications COM(2001)582 and COM(2003)726 on EU company taxation presented a long-term strategy to tackle the corporate income tax obstacles in the Internal Market by providing multi-jurisdictional companies with a consolidated tax base for their EU-wide activities for corporate taxation purposes. This comprehensive approach relies on a number of crucial steps such as delineating the CTB and choosing the mechanism for apportioning the multinationals' tax bases between the relevant Member States, so that they can then apply the national corporation tax rate to their respective shares. This work systematically addresses some of the fundamental questions that arise when considering the design of a consolidation + apportionment system for sharing multinationals' consolidated profits between EU Member States.

Corporate Income Taxation of Multinationals and Unemployment

Abstract: Within a two-country model with involuntary unemployment, this paper investigates corporate income taxation under separate accounting versus formula apportionment. In contrast to separate accounting, under formula apportionment the corporate tax policy causes a fiscal externality which goes back to unemployment. This unemployment externality is the lowest when the apportionment formula does not contain a payroll factor. It tends to compensate other externalities such that tax rates become inefficiently low. In an empirical calibration, we show that the transition from separate accounting to formula apportionment improves welfare and reduces unemployment. The welfare increase is the strongest under a pure sales formula.

Getting the Math Right: Why California Has Too Many Seats in the House of Representatives

Abstract: Over the last 40 years of "one person, one vote" jurisprudence, the Supreme Court has distilled a stable and predictable test for resolving the basic numerical issue in equal representation: how much population difference between districts is permissible? Yet there remains one area of representation into which the Court has refused to venture: apportionment of Congress. In its only opinion on the mechanics of the decennial of apportionment, the Court deferred to Congress. It deferred because, unlike districting, it could not find a single workable measure for apportionment. But the reason it could not find such a measure was that it had made a mathematical error. This Article corrects that mistake and, in the process, shows that the measure of representation for districting should be applied to apportionment. The result is a unified approach to measuring and evaluating disparities in these two types of representation. This unified approach leads to a method of apportionment unlike any used in United States history. In particular, this approach means three fewer representatives from California and one more from each of South Dakota, Delaware, and Montana, among other changes. In general, it means larger states lose representative and smaller states gain. Overall, however, my proposed apportionment method better implements the Court's unwavering adherence to the principle of equal representation. I. INTRODUCTION "One person, one vote" sounds like a simple mathematical equation. Actually, it isn't quite that easy, but over the last forty years, the Supreme Court has distilled a fairly stable and predictable test for resolving the basic issue of equal representation: how much population difference between districts is permissible? In one area of representation, however, the Court has gotten the math wrong. In its only opinion on the decennial apportionment of Congress, the 1992 case U.S. Department of Commerce v. Montana,1 the Court punted. Rather than apply its well-established test from the districting cases, the Court deferred to Congress on the ground that different ways of measuring equality of representation produced different apportionments, and thus Congress, rather than the Court, should choose the best measure.2 Unfortunately, that conclusion was based on a mathematical error. As an abstract matter, applying the districting test to apportionment makes sense. Apportionment and districting are opposite sides of the same coin. In districting, one has a fixed number of representatives, and the geographic area must be cut into pieces to accommodate them. In apportionment, the geographic area is already divided into states, and the representatives must be parceled out among the divisions. In both instances, the goal is "equal representation for equal numbers of people."3 In both instances, the same test should apply. But when the Court tried to apply the districting test to apportionment, it was misled by its mathematical mistake. Relying on numbers provided by the parties, the Court thought it was looking at a calculation of relative deviation-the test used in the districting cases-when it was not.4 Instead, it was looking at a different computation, and, not surprisingly, this alternative computation produced results that conflicted with other indications the Court had.5 The Court thus concluded that the relative deviation test could not be applied to apportionment because the results that the Court reached under the test sent mixed signals about the appropriate measure of representation.6 This Article does the mathematics correctly. It provides a unified account of "one person, one vote" for both the districting cases and the apportionment of Congress, explaining why the same measure of "one person, one vote"-relative deviation-should apply to both districting and apportionment. I argue that the Court may be constitutionally required to apply this test in the apportionment context, and I demonstrate the method of finding the apportionment that best satisfies the requirement. …

Separate Accounting vs. Formula Apportionment: A Private Information Perspective

Abstract: Should countries calculate tax liabilities for multinational firms using separate accounting methods or apportionment formulas? Separate accounting methods initiate distortions through transfer pricing decisions. Apportionment formulas initiate distortions through production decisions. Both types of distortions are due to asymmetric information between the multinational and the relevant tax authorities over the value of cross-border transfers. In this paper, I explicitly model the role of private information in two tax competition games: one in which tax liabilities are calculated under separate accounting and transfer prices are audited and one in which tax liabilities are calculated under formula apportionment. I show that differences in after-tax firm profit and tax revenues depend on the accuracy of the governments' auditing technology and non-monotonically on the firms' private information.

How would formula apportionment in the EU affect the distribution and the size of the corporate tax base? An analysis based on German multinationals

Abstract: This paper analyses the effects of introducing a common EU tax base with formula apportionment on the size of the EU wide tax base and on the distribution of the tax base between the EU member countries. We use a combined dataset of Deutsche Bundesbank's Foreign Direct Investment data (MiDi) and corporate balance sheet data (Ustan and Hoppenstedt) for the tax base estimations. The data is used to construct i) a separate accounting and ii) a formula apportionment tax base for the firms in the sample. Our results suggest that due to border crossing loss-offset, the EU wide corporate tax base represented by our data sample shrinks significantly. Smaller countries which are usually considered to attract book profits under the current system, i.e. Ireland and the Netherlands, tend to lose a larger part of their tax base than larger countries like Germany, Italy, France or Great Britain. However, these results should be evaluated in the light of the limitations of the data used in this study since our analysis is based on German FDI data only. Furthermore, the calculations do not take into account behavioural responses of companies caused by such a system change.

Risk Apportionment Methodology Based On Functional Analysis

Abstract: This paper intends to develop a risk apportionment methodology using functional description in order to comply with the safety targets required by the railway safety directive. A state of the art of risk apportionment strategy in various critical domains is presented and discussed. Our contribution is based on a hierarchical functional decomposition and a safety apportionment to these functions.

Assessment of eutrophication in estuaries: Pressure-state-response and source apportionment

Abstract: The National Estuarine Eutrophication Assessment (NEEA) Update Program is a management oriented program designed to improve monitoring and assessment efforts through the development of type specific classification of estuaries that will allow improved assessment methods and development of analytical and research models and tools for managers which will help guide and improve management success for estuaries and coastal resources. The assessment methodology, a Pressure-State-Response (PSR) approach, uses a simple model for determination of Pressure and statistical criteria for indicator variables (where possible) to determine State. The Response determination is mostly heuristic although research models are being developed to improve this component. The three components are determined individually and then combined into a single rating. In addition to the PSR approach, it is also valuable to identify and quantify the anthropogenic nutrient input sources to estuaries so that management measures can be targeted for maximum effect. Since nitrogen is often the limiting nutrient in estuarine systems, the sources of nitrogen have been determined for eleven coastal watersheds on the U.S. east coast using the WATERSN model. In general, estuaries in the Northeastern U.S. receive most of their nitrogen from human sewage, followed by atmospheric deposition. This is in contrast to some watersheds in the Mid-Atlantic (Chesapeake Bay) and South Atlantic (Pamlico Sound) which receive most of their nitrogen from agricultural runoff. Figure 1. Conceptual model of eutrophication.

Parameterized integer programming models for multifactors representatives apportionment

Abstract: This paper develops parameterized integer programming models for the problem of multifactors representatives apportionment. In the light of the idea of the optimal uniform approximation theory, we formulate such apportionment problem as three mathematical models. In all of the models, the total number of representatives is regarded as an adaptable parameter, the unfair degree of apportionment is evaluated using the norm-∞ of the vector, and the social characteristics of the different “units” are described by introducing the concept of the factor level matrix. In addition, we also attempt to describe some natural properties of each member in our models. By solving the proposed models, we can obtain an apportionment scheme which ensures that the deviation of the real representative number shared by each unit to the ideal one is as even as possible besides that the obtained apportionment scheme is optimal from mathematical point of view. For the solution of the models, so-called grid search algorithms are presented. A large amount of numerical experiments provide some helpful suggestion for the applications of the models.

Company-tax coordination cum tax-rate competition in the European union

Abstract: This paper reviews the recent theoretical literature that analyses the European Union’s policy to eliminate preferential corporate tax regimes and the proposal to introduce a consolidated EU tax base with formula apportionment for the taxation of multinational firms. Since neither proposal includes a harmonisation of corporate tax rates, a core issue is how tax competition between member states will be affected by these partial coordination measures. The conclusions from our review are supportive of the EU’s ban on preferential tax regimes, but the economic incentive effects of a switch to formula apportionment are found to be ambiguous.

Should the States Determine Their Own Tax Destinies?: Federalism in the 21st Century

Abstract: The author says that Congress needs to be more assertive on state tax issues to improve U.S. competitiveness with other nations. Congress should mandate uniform apportionment formulas and uniform rules on carryback and carryforward of net operating losses, the author suggests.

Indirect cost apportionment program

Abstract: PROBLEM TO BE SOLVED: To provide an indirect cost apportionment program, capable of finding common apportionment indexes for a number of business actions and performing accurate indirect cost calculation with a minimized number of apportionment indexes. SOLUTION: Apportionment quantity C kj (i) using apportionment index Dk is estimated for each business action Ai. Apportionment indexes Dk satisfying a condition e k (i) k (i) having a minimum e k (i) is taken therefrom for each business action Ai. When those satisfying this condition are not found, apportionment index Di is selected. When indexes D k (i) having correlations are extracted, they are unified to the apportionment index providing the smaller e k (i) . When each index D k (i) is different from all the others, the index Di is adapted for each Ai. The combination of the new apportionment index Dk and the apportionment index Di is set as a new apportionment index. COPYRIGHT: (C)2007,JPO&INPIT

The U.S. Worldwide Interest Apportionment Rules: Ready, Set, Wait

Abstract: In this report, Cunningham reviews the issues corporate taxpayers should consider when deciding whether to make the one-time election to apportion interest expense based on the principles of worldwide fungibility. While the election, enacted as part of the American Jobs Creation Act of 2004, cannot be made until the first tax year beginning after December 31, 2008, Cunningham explains why taxpayers should begin to determine whether they intend to make the election and, if they do, to organize their affairs to maximize the benefits of the election once they make it.

May It Please the Court? The Solicitor General's Not‐So‐“Special” Relationship: Archibald Cox and the 1963–1964 Reapportionment Cases

Abstract: Forty-two years ago, the Warren Court decided the jurisprudential progeny of Baker v. Carr.1 Six cases, headed by Reynolds v. Sims,2 continued to remake the legal landscape of legislative apportionment using the “one person, one vote” principle. For President John F. Kennedy's Solicitor General, Archibald Cox, the Reynolds decisions were dangerous. He feared they would precipitate a constitutional crisis that would underscore why Justice Felix Frankfurter, his mentor, had urged his judicial colleagues to avoid entangling their institution in the “political thicket” of legislative apportionment.