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First Page

915

Last Page

948

Document Type

Article

Abstract

This Article will describe in greater detail the basic contours of such a reform. Before doing so, Part II describes the existing employment tax rules, focusing on the various ways they apply to a self-employed individual. Part III explains how certain self-employed individuals can use the rules to limit their employment tax base and the tax they owe. Part IV describes the distortions and inequities that are produced under the current employment tax rules. Part V recounts legislative efforts to isolate labor income and shows how those efforts came to bear fruit in the GILTI rules and elsewhere in the 2017 Tax Act. Part VI describes a framework for reform inspired by the GILTI rules. Part VII concludes.

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