The customs sanctions of the EU-27 are not harmonized – the sanctioning of customs offences is still the task of the twenty-seven Member States and their national legislation. The US has attacked the purely national customs sanctions of the EU as break of the WTO rules in the WTO Dispute...

This article continues what has now become a comprehensive series examining the new U.S. reporting and withholding system for foreign account tax compliance. Part VI provides a new four-point analysis to determine if an FFI or USFI has a withholding tax liability for pass-through payments under...

While on one side India and its citizens have been grappling with black money and blaming the Government for being unable to come out with the means to effectively tackle the social menace, on the other hand statutory provisions effectuating the Government intent to come to terms with the...

This article examines the recent series of criminal prosecutions against tax professionals and offshore bankers. These criminal cases, brought against the largest Swiss bank (UBS), the oldest Swiss bank (Wegelin), one of the largest accounting firms in the world (KPMG), as well as numerous...

Many people — perhaps most — want to make money and lower their taxes, but few want to unabashedly break the law. These twin desires have led to a range of strategies, such as the use of “paper corporations” and offshore tax havens, that produce sizable profits with minimal costs. The...

This Article defines and explores irredeemably inefficient acts — a conceptually distinct and empirically important category of socially undesirable conduct. Though inefficient behavior is, no doubt, pervasive, the standard view holds that inefficient conduct may be converted into efficient...

As most of us are aware, the failure to comply with the tax law can lead to tax penalties, which almost always take the form of monetary sanctions. But tax noncompliance has other consequences as well. Collateral sanctions for tax noncompliance — which apply on top of traditional tax penalties...

Tax evasion has persistently carried severe penalties, although its intended deterrence effect is highly doubtful. We can safely say that it is based on the widely shared assumption among government officials that tax evasion is among the more serious crimes. In other words, the rationale of the...

This Article addresses the legal consequences a taxpayer should consider when deciding whether to comply with the basic requirements of the federal income tax laws. A taxpayer considering noncompliance should consider the government's authority to assert criminal liability, impose civil tax...

The goal of this paper is to explore the perception of Kosovo's citizens of the severity of tax evasion relative to other crimes and abuses. Perception of tax evasion may somewhat clarify the degree of rebelliousness with the tax laws. Using data from a self-administered survey and a personnel...