Ralph V. Switzer

United States Taxation of Virtual World Economies: A Review of the Current Status

The taxation of virtual world economies is uncharted terrain, one that both researchers and government officials are just beginning to scrutinize. Taxes are inevitable in any economy, but what about the increasingly lucrative virtual world economies? The market for virtual goods and services in the U.S. alone is estimated to be between

Low-Cost Multinational Acquisition Financing UsingCollateralized Corporate Obligations

2.9 and

Strategic Design of an Interactive Video Learning Lab (IVL)

3.5 billion annually and is predicted to grow to

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5 billion by 2016. So it is no wonder that governments are beginning to take notice. Experts are divided as to the feasibility of taxation of virtual economies. Most experts agree however that there is significant ambiguity in the current U.S. Internal Revenue Code with respect to virtual worlds. It is unclear if transactions occurring in a virtual world are taxable in the U.S., and the Internal Revenue Service has to date not offered any strong guidance regarding the issue. In this chapter, we argue that virtual transactions are already subject to taxation under current U.S. law, at any point in time that the U.S. Internal Revenue Service should decide to enforce the current law, whether taking place in game worlds or unscripted worlds. This would include virtual-to-virtual transactions as well as virtual-to-real transactions, as the issue at hand is whether or not virtual activity is taxable, regardless of realization, because all goods and services have a fair market value.

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This article proposes an innovative financial transaction that employs a whole business securitization structure to create low-cost sources of acquisition financing. The transaction structure provides U.S. acquirers with a unique form of levered financing by creating a debt–equity hybrid security with option-like characteristics. The security, termed here a collateralized corporate obligation (CCO), creates low-cost capital that can be applied to finance the acquisition of operating assets from which payments on the securities are derived. The proposed transaction enables both public and private companies to structure leveraged transactions at lower rates than available through traditional forms of debt financing. Acquirer returns are enhanced through capital structure changes combined with mitigation of bankruptcy and agency costs. Similar transactions have been effected in the U.K. The feasibility of a CCO transaction is dependent on the ability to enhance creditor rights by shifting the administration of insolvency proceedings to creditor-friendly jurisdictions, such as the U.K. This article examines the financial, legal, accounting, and tax implications of the proposed transaction from a U.S. perspective.

The Myth of the Tech-Savvy Student: The Role of Media Educators in a Web 2.0 World

The purpose of this study was to research elements necessary for design of an interactive video learning lab (IVL) for business courses. A properly designed interactive video-learning lab will provide state-of-the-art training and educational materials, in a facility open twenty-four hours a day if needed. With the self-paced, personalized learning available with IVL, learning times can decrease while retention is increased. Using available courseware individualized instruction can be offered on topics not currently covered in the business curriculum.