Smart contracts are the latest twist on automated programming. Their tax implications are still emergent: regulators may seek to fight, join, or try to dominate the market for virtual assets in direct competition with the ambitions of private law orders. This paper reviews the technology to date...

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

Every nation has an interest in sharing the gains they help create by participating in globalization. If governments fail to claim an adequate share of these gains, they will be forced to look ever more intensely to personal taxes on their own already-burdened citizens. Yet because of the...

The OECD Programme of Work on the tax challenges arising from the digitalization of the economy comprises a so-called GloBE (Global Base Erosion) or Pillar Two proposal, consisting of a series of measures aimed at establishing a floor to tax competition by achieving minimum taxation of the...

American emigrants face many consequences from the extraterritorial application of U.S. taxation and banking policies. Their names, addresses, and Social Security numbers are collected, placed on lists of “suspected U.S. persons,” and submitted to a “Crimes Enforcement Network.” They...

We present four important dimensions to international tax policy from a tax-systems perspective, stressing that non-rate/base tax policies can have different cross-jurisdictional spillover effects than changes in tax rates. The dimensions are the allocation of global income among taxing...

When a debtor goes bankrupt and limited assets have to be divided between competing creditors, should unpaid taxes owed to the government be paid before the debts owed to other creditors? This Article defends the notion that some tax debts should be awarded priority. Insofar as bankruptcy...

In the past year, a number of new financial transactions (such as the Fantex, Upstart and Pave transactions) have emerged that allow individuals to raise funds by offering a percentage interest in their future earnings. Unlike traditional lending arrangements, these structures essentially enable...

It comes as no surprise to any observant person in this country that there is a wide disparity in our federal income tax treatment of persons who have differing incomes and financial resources. But while much has been written on tax law complexity and inefficiency, little or nothing has been...