Copley v. United States involved a question at the intersection of tax law and bankruptcy law: can a debtor invoke bankruptcy exemption rules to shield an anticipated income tax refund from offset by the Internal Revenue Service? When the Fourth Circuit Court of Appeals was presented with this...

Decisions by firms and individuals on the extent of their tax payments have generally been treated as separate choices. Empirically, a positive relationship between corporate and personal income tax evasion can be observed. The theoretical analysis in this paper shows that a manager's decision...

This article asks whether tax planning advice can ever be effectively regulated by the IRS. The article first explores whether tax advice differs in kind from other forms of legal advice. Secondly, it looks at the clear regulatory distinction between the treatment of return preparation advice...

Driven by international trade and investment, and connected by family and technology, New York and New Jersey small businesses are expanding their businesses offshore. Entrepreneurs transfer property, cash, and other assets overseas or to foreign holding corporations to conduct everyday business...

We explore the role of tax administrations in the fight against inequality through data analysis of a survey consisting of 71 questions that we have designed and sent to the tax administrations of all EU Member States. The survey focuses mainly on the capacity concerning the enforcement of tax...

There is not a “Global Code” that encodes the duty of cooperation between tax authorities in the world, concerning the global tax system. This article addresses this issue by proposing a global Code of administrative cooperation in tax matters including both tax relations: between States,...

The IRS has published a nonacquiesence to the tax court's decision in Estate of Bartell. That case held that a non-safe-harbor improvements exchange qualifies for section 1031 nonrecognition. This Article considers the effect that the nonacquiesence might have on taxpayers who would otherwise...

Small firms suffer far more than large firmsSuccessive governments have promised to reduce business red tape, whilst doing nothing about it. In fact, with regard to the tax system, ever-greater numbers of taxes and ever-greater complexity have increased burdens on businesses by turning firms...