Showing posts with label organizational forms. Show all posts
Showing posts with label organizational forms. Show all posts

Sunday, February 17, 2013

To Limit Corporate Tax Avoidance, Tax Investors - Bloomberg

Income Tax rates by Country based on OECD 2005...
Income Tax rates by Country based on OECD 2005 data. "OECD Tax Database". Organisation for Economic Co-operation and Development . . Retrieved 2007-01-30 . (Photo credit: Wikipedia)
To Limit Corporate Tax Avoidance, Tax Investors - Bloomberg:

Thoughts?  
"International companies have so much discretion in allocating costs and revenues across their dispersed units that the corporate tax base is unavoidably slippery -- all the more so when governments promote that very slipperiness in an effort to attract investment.....Why fight it? The best strategy to deal with international tax avoidance is what we have recommended: Cut corporate taxes and increase taxes on individual investment income (dividends and capital gains) instead. It’s much harder for individuals to arbitrage away their tax obligations than it is for companies operating across borders. This way, corporate profits are still taxed -- but on a simpler, less distorting basis than the typical corporate tax code provides."

Mmm...a great essay for some class.   Finance?  Econ?  Tax?  All of the above?  
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Friday, June 19, 2009

Turning Nonprofits into For-Profits - BusinessWeek

Time to rewrite my notes again to incorporate these new organizational forms.

Turning Nonprofits into For-Profits - BusinessWeek:
"Social enterprises...often don't fit neatly into existing ownership structures. Those that register as nonprofits have trouble tapping private capital to expand, while for-profit companies risk compromising their missions because they must put shareholders' returns first. But growing interest in hybrid business models has spurred recent efforts at the state level to create new corporate structures that allow entrepreneurs to integrate nonfinancial goals into for-profit businesses..

...known as the Low-profit Limited Liability Company (or L3C), is intended for companies that put their missions before profits. The structure lets them qualify for "program-related investments" from foundations—loans or investments that further a foundation's goals and also may yield financial returns. "

From the NonProfitBlog:

"The low-profit, limited liability company, or L3C, is a hybrid of a nonprofit and for-profit organization. More specifically, it is a new type of limited liability company (LLC) designed to attract private investments and philanthropic capital in ventures designed to provide a social benefit. Unlike a standard LLC, the L3C has an explicit primary charitable mission and only a secondary profit concern. But unlike a charity, the L3C is free to distribute the profits, after taxes, to owners or investors.

A principal advantage of the L3C is its qualification as a program related investment (PRI), an investment with a socially beneficial purpose that is consistent with and furthers a foundation’s mission. Because foundations can only directly invest in for-profit ventures qualified as PRIs, many foundations refrain from investing in for-profit ventures due to the uncertainty of whether they would qualify as PRIs or use costly time and resources to acquire a Private Letter Ruling from the IRS to verify that the venture is a valid PRI."


I can definitely see this as being useful. The ability (even if never occurs) to get money back at some point would likely be a very strong selling point to contributors. Indeed, I can see this as something BonaResponds or likely better our student run money management class could look into in the future if we were to truly have the time/desire to maximize our impact.