Equating U.S. Tax Treatment of Dividends and Capital Gains for Foreign Portfolio Investors

The U.S. tax law equates the tax rate on dividends and long‐term capital gains on stock owned by U.S. citizens and residents. However, the taxation of these two types of rewards in the hands of foreign portfolio investors remains dramatically different from each other, with the capital gain being fully exempt. Several reasons support this article's proposal to no longer exempt these gains. Extending finance theory and prior normative tax research, this article argues that foreigners’ portfolio dividends and capital gains should be taxed in the same manner because they are economically equivalent and emanate from the same source. Three recent empirical developments also support repeal of the foreigner's exemption. First, there is now extensive use by U.S. corporations of stock repurchases—which are taxed to selling shareholders as capital gain—as a form of corporate payout that was in the past primarily accomplished through dividends. Second, foreign ownership of U.S. stocks has continued to increase, with an estimated one‐third of these stocks owned by foreigners. Third, the modern tax compliance environment—including aspects of the Foreign Account Tax Compliance Act that apply to foreigners—reduces past congressional and academic concerns about enforcing the taxation of foreigners’ portfolio gains.     

Physical,Social, and Perceived Availabilities of Alcohol and Last Month Alcohol Use in Rural and Small Urban Communities

This study seeks to provide a greater understanding of the factors that determine the perceived availability of alcohol and its role in predicting adolescents’ alcohol use. Participants were 151,703 7th–12th grade students (50% female) from a sample of 219 rural communities across the United States, with oversampling for predominantly Mexican-American and African-American communities. Multilevel analysis was used to estimate the perceived availability of alcohol as a function of physical and social availability measures and individual and community-level control variables. Physical availability was measured as the number of alcohol outlets in the community and whether beer and wine were sold in non-liquor stores. Social availability measured the availability of alcohol from social or family groups. Last month alcohol use was then estimated as a function of physical, social and perceived availabilities and control variables. Physical availability had little relationship to perceived availability or recent alcohol use while social availability was a strong predictor of both. Perceived availabilities at the individual and community levels were significant in predicting last month alcohol use. The findings suggest that altering both perceived and actual availability of alcohol can potentially have strong effects on the levels of adolescent alcohol use.     

Legacies of Saleem Shah

Saleem A. Shah made seminal and substantive contributions to psychological knowledge, theory, and practice in corrections and the law. He assumed a role as instigator of research and generous colleague in a vast range of psychological-legal activities. Current clinical practices and conceptual frames of reference in legal and correctional psychology reflect the conscience, involvements, and ideas of Saleem Shah.     

A systems analysis of youth in acute and subacute therapeutic residential care

The Arkansas Department of Children and Family Services (DCFS) has reduced the use of therapeutic residential care (e.g., group homes, residential treatment centers) for youth placed in child welfare. Youth in acute or subacute congregate care for 30 or more days without Medicaid now are of particular interest. This is a longer-term psychiatric program, typically 3 to 6 months. The project team conducted a systems analysis to determine the specific characteristics and levels of need for 42 youth so that DCFS can more effectively serve these youth in the least restrictive form of treatment possible.