Hiroyuki Kohyama

S.J.D. Candidate

hkohyama at law.harvard.edu

Dissertation

Reconsideration of the Taxation of Investment Income: Discount rates for a government

Why does a government impose tax? One answer would be "to raise revenue". Nowadays, many governments are facing serious budget deficits, including the US and Japan. If we fail to take into account the possibility that the government can raise more revenues without harming taxpayers, we ignore way of reducing government deficits that could minimize the costs of deficits reduction to the public. The main purpose of my dissertation project is to reconsider the taxation of investment income from the viewpoint of governments (revenue). The established tax theories about the taxation of investment income suffer from two problems. First they ignore the difference between the discount rate for governments and that for taxpayers. Second they ignore the impact of inflation. By taking into account these two factors, I will reconsider several anti-deferral provisions (e.g. CFC rule) and accrual basis provisions (e.g. OID rule) in the tax code.

Fields of Research and Supervisors

Tax Law and Tax Policy, with Professor Daniel Halperin, Harvard Law School, Overall Faculty Supervisor
Federal Budget Process, with Professor Howell Jackson, Harvard Law School
Economic Analysis of Taxation, with Professor Louis Kaplow, Harvard Law School

Education

Harvard Law School, S.J.D. Candidate 2005-Present
Harvard Law School, LL.M. 2005
University of Tokyo, Japan, LL.B. 2003

Appointments and Fellowships

University of Tokyo, Graduate Schools for Law and Politics, Japan 2003-2004, Research Associate

Additional Information

Languages: English(fluent), Japanese(native), German(readable)