Collected References, available on-line as 27-Oct-13 References for: Gio Wiederhold: Valuing Intellectual Capital, Multinationals and Taxhavens Springer Verlag 2013 VIC Citations This list includes all the references cited, as well as others that I have persused. For general information, I chose a recent publication for citation, trusting that it will be easier to locate and cite earlier work. As is common in tax matters, opinions abound. Refereed material is italicized. Entries cited and listed in the Reference section of Valuing Intelectual Capital have [bold identifiers]; entries considered, but not cited are marked ‡. Entries marked † were used for [W:06] . Transcription into the spreadsheet for VIC are marked [xls/worksheet]. Shaded text is to be omitted in publication, but helpful for search or as an aide de memoire. I am dding {chapter.section} references AAAAAAA [Aaron:13B] Henry J. Aaron: Tax Reform? Between a Rock and a Hard Place; Huffington Post, Brookings, 15 Jan. 2013. The 1986 reforms shifted $1T (adjusted) from individuals to Corportations over 10 years. Mobility of capital and the proliferation of multinatinal companies prevents such a solution now. Must raise personal income tax.{VIC Ch10.7.4} [Aaron:13G] Henry J. Aaron: You Get What You Pay For: Lessons From the IRS Scandal; Brookings, 31 May 2013. Only 1% of returns is audited. $450B is uncollected. Each dollar spent auditing yields $8. {VIC Ch8,7.3} [AbahoonieA:10]‡ Edward Abahoonie and Liah Alfonso: Deferred taxes on foreign earnings: A road map; Price Waterhouse Coopers (PwC), Dec.2010, updated 2012 www.pwc/us/tax. (with a nice picture of Luzern, Switzerland). {VIC Ch2.6} [Abba:97]† Wayne Abba: "Earned Value Management: Reconciling Government and Commercial Practices"; Program Manager, Vol.26, pp.58–69. {VIC Ch8.7.2} [AbramitzkyB:04] Ran Abramitzky and Fabio Braggion: Malthusian and Neo-Malthusian Theories; Oxford Encyclopedia of Economic History, Oxford University Press, 2004. At Stanford University.{VIC Ch9.4.5} [Acritas:10] Rankings of law firms employed for cross-border litigation and deals; BBW 27Sep.2010, p20. {VIC Ch8.7.4} [ACS360:09] Financial Accounting Standards Board: Property, Plant, and Equipment; Accounting Standards Codification 360-10-35-4, Depreciation, Version 3.0, 1 July 2009. Depreciation is a method of allocation, not of valuation. {VIC Ch3.4} [Actionaid:11] ActionAid: Addicted to tax havens, the secret life of the FTSE 100; ActionAid, UK, Oct.2011, http://www.actionaid.org.uk/doc_lib/addicted_to_tax_havens.pdfl. {VIC Ch8.5.3} [Adams:97] James D. Adams, 1997. "The Structure of Firm R&D and the Factor Intensity of Production“; NBER Working Papers 6099, National Bureau of Economic Research, Inc.; also Working Papers 97-15, Center for Economic Studies, U.S. Census Bureau. {VIC Ch5.7} [Adams:12] Scott Adams: Dilbert; Famous Quotes, Retrieved Jan. 2012. “There are many methods for predicting the future. For example, you can read horoscopes, tea leaves, tarot cards, or crystal balls. Collectively, these methods are known as `nutty methods.’ Or you can put well-researched facts into sophisticated computer models, more commonly referred to as `a complete waste of time’." {VIC Ch5.1} [ADLittle:85] ADLittle: Development of a Methodology for Estimating the Taxpayer Paperwork Burden; IRS, June 1988. Time cost for individual and business taxpayers $1813M, $3,614M = total 5,427M hours. [xls/irs] {VIC Ch8.2.2} [AF:04] The Appraisal Foundation: Uniform Standards of Professional Appraisal Practice; Standard 9, 2004 Edition. {VIC Ch.3.3} 1 [AgarwalG:99] Rajshree Agarwal and Michael Gort: First Mover Advantage and the Speed of Competitive Entry, 1887-1986; National Bureau of Economic Research (NBER), Sep.1999; SSRN library http://ssrn.com/abstract=167330. {VIC Ch7.4.1} [AghionH:94] Philippe Aghion and Peter Howitt: "Growth and Unemployment“; Review of Economic Studies, Wiley Blackwell, Vol.61 no.3), pp.477-494, July 1994; CEPR Discussion Papers 577. [AGN:08]‡ AGN International: The AGN European Region - 2008 Corporate Tax Survey, 2008 . Annual surveys of ominal and effective tax rates. [xls/taxrates] {VIC Ch9..4.2} [Aiken:09] Alex Aiken: Measure of Software Similarity Software; MOSS software, 2009, . {VIC Ch5.1.i} [AJCA:04] U.S. Congress: American Jobs Creation Act; H.R.4520, Title VIII, Subtitle A, Section 422 (a) “965(a)(1)”, 2004. Sect 801 deals with inversions. {VIC Ch.2.5} {VIC Ch.2.7} [Albinus:12]‡ Phil Albinus: Fleeing Dodd-Frank, Hedge Funds Follow the Sun; Advanced Trading, 5 Jan 2012. Taxhavens protect bonuses. See [Kahn:12] .As of early November, the number of funds located in Malta had grown to more than 500 with 8 billion euros ($10.7 billion) under management from 165 funds with less than 5 billion euros under management in 2006, according to the Malta Financial Services Authority, or MFSA. [AlcockBG:09] Alistair Alcock, John Bird, and Steve Gale: Alcock, Bird and Gale on the Companies Act 2006; Jordans, 2009. s.172 CA 2006, "to promote the success of the company for the benefit of its members as a whole". It sets out six factors to which a director must have regards in fulfilling the duty to promote success. These are: 1. the likely consequences of any decision in the long term, 2.the interests of the company’s employees, 3.the need to foster the company’s business relationships with suppliers, customers and others, 4.the impact of the company’s operations on the community and the environment, 5.the desirability of the company maintaining a reputation for high standards of business conduct, and, 6.the need to act fairly as between members of a company. This represents a considerable departure from the traditional notion that directors' duties are owed only to the company. [Alderman:10] Liz Alderman: ”In Ireland, Low Corporate Taxes Go Untouched”; The New York Times, 25 Nov.2010. “The corporate tax is one of the pillars of Ireland’s economy, because it drives exports and jobs, and creates tax revenues for the government”; said Paul Duffy, a vice president at Pfizer in Ireland, one of the biggest multinational employers here. Raising the tax could scare away companies and “would damage a recovery and our ability to repay the massive debts we’ve taken on”; he said. /Critics, however, say that in addition to siphoning business from countries with higher corporate tax rates, some multinationals operating under Ireland’s tax rules use complicated schemes to move profits in and out of subsidiaries there. In some cases, that allows them to lower their effective tax rate, they say. /That has opened Ireland to criticism from countries like Germany, where Chancellor Angela Merkel must justify why taxpayers should help pay for another bailout package. The argument is that Ireland could be collecting more money from the companies it has lured. /Tax rates have become a contentious issue in Europe, where governments are competing as never before to lure badly needed foreign investments as the economic crisis weighs on growth. [AlmDM:04] James Alm, John Deskins, And Michael McKee: Tax Evasion and Entrepreneurship: The Effect of Income reporting Policies on Evasion; 97th Annual Conference of the National Tax Association, Minneapolis, MN, Nov.2004. An audit rate of 10% vs 30% doubles non-compliance. [Allan:11] Robert B. Allen (allen@acm.org): Information: A Fundamental Construct; . “The greatest advantage of the corporate form of business organization is the limited liability protection accorded its owners. Taxation of corporate income is the price of that protection. This price must be worth the benefits since, according to the Internal Revenue Service (1996), corporations account for less than 20 percent of all U.S. business firms, but about 90 percent of U.S. business revenues and approximately 70 percent of U.S. business profits. The benefits of limited liability independent of those enjoyed by shareholders, the flexibility of change in ownership, and the immense ability to raise capital are all derived from the legal entity status accorded corporations by the law. This equal status requires that corporations pay income taxes.... . [AmdahlBB:64] Gene M. Amdahl, Gerrit A. Blaauw, and Frederick P. Brooks jr.: "Architecture of the System/360"; IBM J. R&D, Vol.8 no.2, April 1964, pp.87-101. Allocation of value to three types of development efforts. [AmirLS:03] Eli Amir, Baruch Lev and Theodore Sougiannis:: “Do financial analysts get intangibles?”; European Accounting Review, 2003, pp.635-659. Deals with access to intangible info by sector. [AmrominHLS:05]‡ Gene Amromin, Paul Harrison, Nellie Liang, and Steve Sharpe: How Did the 2003 Dividend Tax Cut Affect Stock Prices and Corporate Payout Policy?; Finance and Economics Discussion Series, Federal Reserve Board, Washington, DC, working paper 57, Sep.2005. [Anderson:08] Chris Anderson: “Free! Why $0.00 is the future of business”; Wired Magazine, Vol.16 no.3, 25 Feb2008,http://www.wired.com/techbiz/it/magazine/16-03/ff_free?currentPage=all. [Anderson:09] Eric Anderson: Take the Money and Run, Sovereign Wealth Funds and the Demise of American Prosperity; Praeger Security International, 2009. Stanford Library checkout, bought it later. Focus on Souvereign wealth funds, in the city.. Chap 5 has merger rules, Chap 6 on tax 2008 plans [xls/industry]‡ [Anderson:10]‡ David Anderson: Remodeling Pre/Post Conflict Development Assistance for Weak and Failing States; Entrepreneurship and Expeditionary Economics, Kauffman, Command and General Staff College Foundation, 2010. , cites [Ketsdever:10]‡ 3 [AndersonC:00] Sarah Anderson and John Cavenaugh: Top 200: The Rise of Corporate Global Power; Institute for Policy Studies, 2000. Used wrong metrics [Woolf:04] [Andriessen:03] Daniel Andriessen: Making Sense of Intellectual Capital: Designing a Method for the Valuation of Intangibles; Butterworth-Heinemann, Dec. 2003. Ex KPMG author, 25 methods sketched covering Management, human resources, company performance, accounting, and business transactions. Methods are critiqued; no quantitative results. [AndrusP:09] Joseph L. Andrus and Irving H. Plotkin: PKN Alert United States – Prsident Obama’s proposal to limit shifting of income through intangible property transfers; Pricing Knowledge Network, PricewaterhouseCoopers, 22 May 2009. Calls §936(h)(3)(B) a laundry list, but laundry lists do not have an entry for `other similar items’ [AngusNSW:10] Barbara Angus, ToAndruem Neubig, Eric Solomon, and Mark Weinberger: “The U.S. International Tax System at a Crossroads”; Tax Analysts, E&Y, 2010. Companies will invest if taxed more. Tables of Fortune 500 global companies. importance of intangibles and services. “Changes to the international tax rules should not be undertaken piecemeal.” [AnkenB:11] F. Anken and J.E. Beasley: Corporate structure optimisation for multinational companies; Omega, 2011. [AnsonA:03] Weston Anson and Chaitali Ahya: How to Make Transfer Pricing Work for IP and Intangible Assets; Int'l Tax Rev., Vol.1514 (2003-2004) [AnsonEa:09] Tim Anson, Nardi Bree, Carl Dubert, Marty Collins, Tom Quinn, and Greg Libkin: Outbound Transfer of Foreign Goodwill and Going Concern Value; Journal of International Taxation; Transfer Pricing Insider, Vol.3 Issue 3, PricewaterhouseCoopers, Nov. 2009. Comment on [IRS-TAM:09]. The TAM, and similarbObama administration proposlas, would significantly narrow transferring a business without paying income tax. [AntosEa:08] Joseph Antos et al.: Taking Back Our Fiscal Future; The Brookings Institution and The Heritage Foundation, 2008, Cut growth of Social Security, Medicare, and Medicaid. [AP:11] AP: Western Union to Pay $220M More in IRS Settlement; Associated Press, Bloomberg Businessweek, 15 Dec.2011. [Appelbaum:12] Binyamin Appelbaum: ”Tax Break Increases Deficit, But May Have a Silver Lining”; The New York Times, 3 Feb.2012. [Applegate:13] Evan Applegate: “Bid/Ask”; Bloomberg Businessweek, 27 May 2013, p.65. [AppleyardFC:06] Dennis R. Appleyard, Alfred J. Field and Steven L. Cobb: International Economics; McGraw-Hill Irwin, 2006. [Arellano:08] Sergio Arellano: Exit Strategies; IRS, 2002, . <> Starting 1999 to 2006 US company with a Possessions corporation transfer assets as a non-taxable contribution (Sect.351) or non-taxable reorganization (sect.361) to a CFH in Bermuda or so. The Puerto Rico operation becomes a subsidiary of the CFH. “A taxpayer may claim that transfers from the § 936 corporation include a significant amount of value in the form of workforce-in-place and that such workforce-in-place is not taxable. Workforce-in-place is properly treated as an intangible under § 936(h)(3)(B), and is therefore taxable under USC § 367(d). Some taxpayers have argued that the workforce-in-place is a part of going concern value that transfers tax free to the foreign corporation. However, to the extent that workforce-in-place can be identified and valued as a distinct asset, workforce-in-place should not be viewed as part of foreign goodwill or going concern value. ”. [Argy:06] Victor Argy: The Postware International Money Crisis: An Analysis; Taylor and Francis, 1981, reprinted 2006 by Routledge. Any changes? Eurodollar reserves in 1976, 222.1B SDR. $485B per Morgan Guarantee [Arnold M:93] Brian J. Arnold & Thomas E. McDonnell: Report on the Invitational Conference on Transfer Pricing: The Allocation of Income and Expenses Among Countries, 7 Tax Notes International, 1507 , 13 Dec.1993 . use of cost sharing by oil companies, equal risk. [ArnoldM:02] B.J. Arnold and, M.J. McIntyre: International Tax Primer; Kluwer Law International, 2002. [Aron:83]† J.D. Aron: The System Development Process, The Programming Team (Part II); Addison-Wesley, 1983. The input to software IP generation, a component of intelectual capital. Coherence and complementarity. [Arora:13] Jaime Arora: Negotiating Transfer Pricing Safe Harbors Will Take More Time, Maruca Says; Tax Notes Today, 5 Jun.2013. Unclear that the concept will be effective as long as sometax havens are left. [Arthur:83]† Lowell Jay Arthur: Programming Productivity; Chapter 8 on Maintenance, Wiley, 1983. [ArthurEa:12]‡ Brian P. Arthur: IRS Issues Final Regulations for Cost Sharing Arrangements; Baker & McKenzie, 9 Jan 2012. The platform approach to transfer pricing is now official. [ASCAP:10] The American Society of Composers, Authors and Publishers: Customer licensees; ASCAP, 2010, [AschhoffS:09] Birgit Aschhoff and Wolfgang Sofka: "Innovation on demand--Can public procurement drive market success of innovations?“; Research Policy, Elsevier, Vol.38 no.8, Oct.2009. pp.1235- 1247. [Asher:09]‡ Mukul G Asher: Needed, a more comprehensive approach to tax havens; Daily News & Analysis (DNA), 9 May 2009. Complete reference from vaishab. [Ashley:10]‡ Sophie Ashley: “Ireland increases withholding tax exemption”; International Tax Review, 01 Nov.2010. [AshrafG:11] Quamrul Ashraf and Oded Galor: “Dynamics and Stagnation in the Malthusian Epoch”; American Economic Review, Vol.101 no.5 Aug.2011. , [AsprayMV:06] William Aspray, Fred Mayadas, and Moshe Y.Vardi (eds.): Globalization and Offshoring of Software; A Report of the ACM Job Migration Task Force, ACM, 2006. An optimistic assessment, ignoring IP rights transfer. [ACM] [AtkinsB:13] Ralph Atkins and Alex Barker: “Robin Hodd tax: A long shot”; Financial Times; 20 May 2013. European plans for a financial transaction levy are likely to be diluted. [Atkinson:11] Robert D. Atkinson: U.S. Corporate Tax Reform: Groupthink or Rational Debate?; The Information Technology & Innovation Foundation, Washington DC (ITIF) report, July 2011, . [Atkinson:12] Robert D. Atkinson: Enough is Enough: Confronting Chinese Innovation Mercantilism; The Information Technology & Innovation Foundation, Washington DC (ITIF) report, 28 Feb.2012, . Several groups: 1. hard core base broadeners to lower corp. tax, programatic base brodeners (keep R&E). 3. Simpler code raising the effective tax, 4. Pragmatic Incentivists as ITIF view tax code as a tool. [AtkinsonS:76] Anthony B. Atkinson and Joseph E. Stiglitz: “The Design of Tax Structure: Direct versus Indirect Taxation”; Journal of Public Economics, Vol.6 no.1-2, 1976, p.55-76. Reprinted in Social Justice and Public Policy, MIT Press, 1983. Parts appeared 1970-1972, Many hurdles. [ATRA:13] U.S. Congress: American Taxpayer Relief Act; HR-8, 3 Jan 2013. [Atwood:07] Margaret Atwood: The Blind Assassin; Anansi, Toronto, 2007. On Kindle. [Atwood:08]‡ Margaret Atwood: Payback (Debt and the Shadow Side of Wealth); Anansi, Toronto, 2008. [Audretsch:95] David B. Audretsch: Firm profitability, growth, and innovation; Review of Industrial Organization, Vol.10, no.5, 1995, pp.579-588. Lag is 4.2 years , leverage for innovatve industries 2.563, for innovative computer companies 4.525. 5 [AudretschL:12] David B. Audretsch and Albert N. Link: “Valuing an Entreprneurial Enterprise”; Small Business Economics, Vol.38 2012, pp.139-145. Shows that 4 typical methods do not work. Says he offers a methodology, but only cestimates number of startups. [Auerbach:99] Alan J. Auerbach: “Measuring the impact of tax reform”; in [Slemrod:99], p.360 . Making incremental changes is more effective than grand ones. [AuerbachF:02] Alan J. Auerbach and Martin Feldstein, eds.: Handbook of Public Economics, Vol.4, North- Holland, 2002. [Auerbach:06] Alan Auerbach: Why have Corporate Tax Revenues Declined” Another Look; CESifo workshop, The Future of Capital Income Taxation, Venice, July 17-18, 2006, updated Dec.2006. Ignores effect of AJCA. [Auerbach:06F] Alan Auerbach: The Future of Capital income taxation ; 2006 Institute for Fiscal Studies Annual Lecture, Sept 2006. at the University of California at Berkeley. found that whereas in 1983 financial corporations accounted for only about 5% of all corporate-tax revenues in America, between 1991 and 2003 they made up roughly a quarter. Kep the Corporate income tax. [Auerbach:05] Alan Auerbach: Who Bears the Corporate Tax, A Review of What we Know; NBER’s Tax Policy and the Economy conference, Sep.2005. Different sizes of corporations, shareholders, and timing. Refers to Harberger. Consders intangible value, but at a modest (50%) increment. A corporate tax distorts, is not desirable. Too much individual capital is tied up in housing. [AuerbachDS:08] Alan Auerbach, Michael P. Devereux, and Helen Simpson: “Taxing Corporate Income”; Mirrlees Review, Reforming the Tax systems for the 21st Century; 2008. Focus on UK. What base, where. [August:13] Jerald D. August: G-20 Finance Ministers Recently Announce Continuing Efforts Towards Achieving Automatic Information Exchange; Mondaq, Fox Rothschild, 26 May 2013. Adopt the Mutual Assistance Convention of 1998, for automatic information exchange, not just TIEAs.? [Aujean:01] Michel Aujean (chair): Company Taxation in the Internal Market; Commission of the EC, 23 Oct 2001. Includes problems with Transfer pricing, and intangibles. [Auletta:09A] Ken Auletta: “Searching for Trouble, Why Google is on its Guard”; New Yorker Magazine, 12 Oct.2009, pp.46-56. Abstract or Audio: [Auletta:09B] Ken Auletta: Googled; 2009. Expands [Auletta:09A] On Kindle. [Austin:08] David Austin: Effects of Gasoline Prices on Driving Behaviour and Vehicle Markets; Congressional Budget Office, Congress of the United States, Jan.2008. [AviYonah:95] Reuven S. Avi-Yonah: “The Rise and Fall of Arm's Length: A Study in the Evolution of U.S. International Taxation”; Va. Tax Rev., Vol.15, 1995, p89. [AviYonah:02] Reuven S. Avi-Yonah: For Haven's Sake: Reflections on Inversion Transactions; University of Michigan Law School, Tax Notes, Vol.95 no.12, June 17, 2002. ??AAAA [AviYonahC:08]‡ Reuven S. Avi-Yonah and Kimberly Clausing: “Reforming Corporate Taxation in a Global Economy: A Proposal to Adopt Formulary Apportionment”; in Paths to Prosperity [FurmanB:08]‡, 2008, pp.319-344, 2008. [AviYonah:12]‡ Reuven S. Avi-Yonah: Statement to Congress; University of Michigan School of Law, Permanent Subcommittee on Investigations, U.S. Congress, 20 Sep.2012. Commensurate, was emphasized in 1986, ignored again by now. Cost-sharing rules, low payment for R&D, high income offshore. Split. CFC look-through regulation misused. Disregarded lower CFCs. Short term loan is only one ploy for repatriation. Blames IRS rules on RAB, override costsharing agreements, treat inatngibles properly. MisvaluationDo aawy with look-through rule and check the box..MS Puerto Rico where US IP rights reside earn on the average 45K/a. [Avril:11]‡ Hillaire Avril: Africa, Emerging Trend Towards Establishing Offshore Tax Havens; Interpress Service (IPS), 17 Aug.2011. [Ayal:75]† Igal Ayal: Simple Models for Monitoring New Product Performance; Decision Sciences, 1975, Vol.6, pages 221-236. Aggregation and repurchase. BBBBBBBB [B. ... ] are references to [W:13] Gio Wiederhold Valuing Intellectual Capital, Appendix B, Laws and Regulations. [B&McK:09] North American Tax Practice Group: Transfer Pricing, Managing Intercompany Pricing in the 21st Century; Baker & McKenzie, 2009. [B&McK:11] 2011 Aug.workshop materials in HMAT.references/2011 Aug.workshop materials in HMAT/references/Baker&McKenzie11 [Babcock:68,94] Henry A. Babcock: Appraisal Principles and Procedures; American Society of Appraisers, 1968, fifth edition 1994. [Bachman:10] Helana Bachman: “Why More U.S. Expatriates Are turning in their Passports; Time Magazine World, 20 March 2010. [Bachman:12] Helana Bachman: “Why U.S. Tax evaders Can no Longer Count on Swiss Secrecy; Time Magazine World, 15 March 2012. [BaerZ:09] Nikolaus Baer and Robert Zeidman @ Zeidman Consulting: Measuring Software Evolution with Changing Lines of Code; VIP-CATA conference 10 April 2009, 24th International Conference on Computers and Their Applications, New Orleans, LA. Cites [Wiederhold:2006] . [BahreeB:12] [xls/taxhavens] [BajajBN:99] : Mukesh Bajaj, Brian Becker, and Jonathan Neuberger: Transfer Pricing and Foreign Exchange Risk; Transfer Pricing Report, Vol.8 no.6, 15 July1999, pp.251-259. Have copy. Hedging, insurance, broaden the interquartile range to account for risk. [BajajDFS:01] : Mukesh Bajaj (Managing Director of Finance and Damages Practice of LECG, LLC), David J. Denis**, Stephen P. Ferris & Atulya Sarin: Firm Value and Marketability Discounts; working paper, SSRN. Managing Director of Finance and Damages Practice of LECG, LLC [Baker:05] Raymond W. Baker: Capitalism’s Achilles heel, Dirty Money and How to Renew the Free Market System; Wiley, 2005. [Baker:07] Leroy Baker: Halliburton Feels Democrat Wrath After Dubai Move; Tax-News.com, New York, 15 March 2007. [Baker:10] Raymond Baker: “Transparence First”; The American Interest, July-Aug.1010. [Baker:11] George Baker: “No Death, no taxes, The libertarian futurism of a Silicon Valley Billionaire”; The New Yorker, 28 Nov.2011. Peter Thiel’s background, attitudes, and plans. [BaldwinK:04] Agglomeration, Integration and Tax Harmonization; European Economic Review, vol.48 No.1 p-23. In [PalanMC:] . [BaltagiR:05] Badi H. Baltagi and Daniel P. Rich: "Skill-biased technical change in US manufacturing: a general index approach“; Journal of Econometrics, Elsevier, Vol.126 no.2), pp.549-570, June. 2005; IZA Discussion Papers 841, Institute for the Study of Labor (IZA). [Banks:10] Nancy Turner Banks: AIDS, Opium, Diamonds, and Empire: The Deadly Virus of International Greed; iUniverse, Kindle , May 2010 [Banner:80] Donald W. Banner: "Pricing the Technology"; Domestic & International Licensing of Technology 1980, T. Arnold and J.T. McCarthy, Eds., Practi(s/c)ing Law Institute, 1980. Not at SUL. The source appears to be an annual treatise by an institute within NYU, but is not now publicly available. ??VVVV [Baran:6x] Paul Baran Baran wrote about in the early 60's: that computer networking would bring about the decline of governments. JM had hoped to ask Kleinrock why it is that we so rarely hear of Paul Baran ("BEAR-en) NNNN [Baranson:78] Jack Baranson: Technology and the Multinationals; Lexington Books, 1978. p. 64. Cited by [Caves:83]‡. Offshore movement of IP. Have chapter around p. 33; also see p.64. [Barber:02] Benjamin R. Barber, A Failure of Democracy, Not Capitalism; The New York Times, July 29, 2002. [BarL:10]‡ Michael Bar and Oksana Leukhina: The Role of Mortality in the Transmission of Knowledge; Journal of Economic Growth, Vol 15 no.4 Dec.2010. Bar is at SFSU Historical study of the years of the plague: 1650-1880. 7 [Barthold:11] Thomas A. Barthold: Response to Lloyd Doggett, containing revenue estimates for a new repatriation under IRC 965; Joint Committee on Taxation, Congress of the United States, 15 April 2011. [BarIlanS:96]‡ Avner Bar-Ilan and William C. Strange: "Investment Lags"; American Economic Review, American Economic Association, Vol.86 No.3,1996, pp.610-622. [BarlettS:00] Donald L. Barlett and James B. Steel: The Great American Tax Dodge, How Spiraling Fraud and Avoidance Are Killing Fairness, Destroying the Income Tax, and Costing You; Little, Brown, and Co., 2000. Have. Diatribe. Belize IRS staff inadequate p.21. No resources to chck EITC. p.27 . IRS cannot track extraterritorial transfers p.55. effect of Vereinsgesetz p67. Few Shjam tranascations get caught p.73 IRS unable to deal with Internet transactions p89.Domonizing the IRS p119, Constraints on IRS personnel p.123.audits of HNWI slow p.164.. sales tax p246. [Barra:98]† BARRA: United States Equity Version 3 (E3); MSCI, BARRA, Berkeley, CA, 1998. [Barrett:12]‡ Paul M. Barrett: “White Shoe Blues”; Bloomberg Businessweek; 23 April, 2012. [Bartlett:81]‡ Bruce Bartlett: Reaganomics: Supply Side Economics in Action; Arlington House, 1981. [Bartlett:06]‡ Bruce Bartlett: Impostor: How George W. Bush Bankrupted America and Betrayed the Reagan Legacy; Doubleday, 2006. [Bartlett:09]‡ Bruce Bartlett: The New American Economy, The Failure of Reaganomics and a New Way Forward; Palgrave McMillan, 2009. [Bartlett:12B] Bruce Bartlett: The Benefit and the Burden, Tax Reform, Why We Need It and What It Will Take; Simon and Schuster, 2012. Have. Excellent, covers all aspects of taxation and the imbalances created. But this three page proposal at the end has no numbers, exactly what he criticizes others about. [xls/taxes] [Bartlett:12G]‡ Bruce Bartlett, GOP: All Talk on Eliminating Tax Breaks – No Action, Fiscal Times, Aug. 24, 2012, http://www.thefiscaltimes.com/Columns/2012/08/24/GOP-All-Talk- on-Eliminating-Tax-Breaks-No-Action.aspx#page1. [Bartlett:12T] Bruce Bartlett: How to Avoid Reinventing the Wheel on Tax Reform; The New York Times, 24, 31 Jan.31, 2012. Avoid gimmicks, and focus on corporate taxation. [Basili:90]† Victor Basili: "Viewing Maintenance as Reuse-Oriented Software Development"; IEEE Software, Vol.7 No.1, Jan.1990, pp.19-25. [BassettCG:09] Barton W. Bassett, William F. Colgin jr., and Neal A Gordon: Veritas v. Commiossioner: Tax Court Decision Exposes Flaws in Common IRS Cost-Sharing Buy-in Theories, Morgan Lewios Tax Practice, Palo Alto, 16 dec. 2009. IRS includes workforce in place, goodwill, Going- concern value. Shows unpreparedness of IRS expert witness [Bastiat:xx] Frederick Bastiat: What is seen and What is Not seen; Essays in The economics of Freedom, What your Professors won’t tell you; Frederick A. Hayek have on Kindle [BathalaMR:84] C.T. Bathala, K.P. Moon, and R.P. Ramesh: “Managerial Ownership, Debt Policy, and the Impact of Institutional Holdings: An Agency Perspective”; Financial Management, Vol.23 no.3, Autumn 1994, pp 38-50. . Percentage of revenue spent on R&D and advertising = 3.5 percent in cross-section [Basse:11] Søren Hetland Basse: Science History and The Future; Royal Danish Library reg.1992, translated and updated 11 Feb.2011, . Developing countries [BassL:83] Frank M. Bass and Robert P. Leone: Temporal Aggregation, the Data Interval Bias, and Empirical Estimation of Bimonthly Relations from Annual Data; Management Science, Vol.29 No.1, Jan.1983, p1-11. Advertisement life is equal to product replacement interval (p.7, quoted by [Berndt:91] [Batelle:73]† Batelle Laboratories: Evaluation of the Implementation of a Medical Information System in A general community Hospital"; report on a study commissioned by NCHSRD, DHS, 1973. [Baum:10] Caroline Baum: The Good Old Bad Days; Bloomberg Businessweek; 6 Sep.2010, pp.4-5. [Baumgarten:09] Daniel Baumgarten "International Outsourcing, the Nature of Tasks, and Occupational Stability – Empirical Evidence for Germany“; Ruhr Economic Papers 0108, Rheinisch-Westfälisches Institut für Wirtschaftsforschung, Ruhr-Universität Bochum, Universität Dortmund, Universität Duisburg-Essen, 2009. [Baumol:72]‡ William J. Baumol: "On Taxation and the Control of Externalities", American Economic Review, Vol.62 no.3, Jun.1972, pp.307–322, JSTOR 1803378 [Basel:06] Basel Committee on Bank Supervision: International Convergence of Capital Measurement and Capital Standards; Bank for International Settlements, June 2006 [Baxandall:12] Phineas Baxandall: Rogues Gallery of Major Corporate Legal Settlements; U.S. PIRG, 17 April 2012. [Baxandall FS:12] Phineas Baxandall, Abigail Caplovitz Field, and Dan Smith: Picking Up the Tab, Average Citizens and Small Businesses Pay the Price for Offshore Tax Havens; CALPIRG, April 2012. Names many companies and has good references. [Baz:09] Aureliano Gonzales Baz: Manufacturing in Mexico: The Mexican In-Bond (Maquila) Program; Banco Nacional de Comercio Exterior, 2009, /nipaguid.pdfl>. [xls/GNP&GDP [BEA:09] BEA: U.S. Direct Investment Abroad: Financial and Operating Data for U.S. Multinational Companies; Bureau of Economic Analysis, U.S. Department of Commerce, [BettendorfvdH:06] Leon Bettendorf and Albert van der Horst, 2006. "Documentation of CORTAX“; CPB Memorandum 161, CPB Netherlands Bureau for Economic Policy Analysis [Bhagwati:06] Jagdish Bhagwati: In Defense of Globalization; Oxford Univ. Press, 2004. At Columbia Univ. Many citation and examples. Not much consistency. No mention of taxhavens. [BharadwajK:97] Anandhi Bharadwaj and Benn R. Konsynski: Capturing the Intangibles, information Week, 22 Sep 1997. Intangibles can be valued. Market value is best Tobin Q-ratio.

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