The worldwide rise of the Value-Added Tax (VAT) over the last half-century is emblematic of the paradox in modern tax systems: their remarkable similarity in the face of divergent political, cultural and social systems. However efforts to introduce VAT-style taxes have frequently been...

Vodafone acquired Hutchison (India) in 2007. Post-acquisition Vodafone has faced a turbulent time dealing with the tax authorities. The liability on Vodafone to withhold Capital Gains Tax was upheld by the Bombay High Court but subsequently rejected by the Indian Apex Court. However, the matter...

Funding higher education is among the critical financial decisions made by individuals and families. There are myriad options. Yet, the conventional wisdom — namely using Section 529 Plans — may not be the optimal vehicle to effectuate this goal. Therefore, this Article discusses various...

Confidence Games provides an account of the wave of tax shelters that occurred at the turn of the twenty-first century. During this period, some of America's most prominent law and accounting firms created and marketed products that enabled the very rich — including newly minted dot-com...

This past July 1 marked a Tax Shelter anniversary. On that date twelve years ago, the IRS issued Notice 2003-47, challenging the deferral of income by corporate executives using the so-called ECS, an acronym variously interpreted to mean the Executive Compensation Solution, the Executive...

The process used to select the hosts of the Olympic Games is under increased scrutiny due to the withdrawal of many cities from the 2022 Winter Olympic Games host selection process, and the selection of hosts with questionable human rights records. Scholarship, particularly legal scholarship,...

When examining a corporate taxpayer, the IRS often seeks special accounting documents called tax accrual workpapers. These workpapers often contain privileged documents, but the IRS does not care. It believes it is entitled to the documents despite that the work product doctrine protects the...

This book explores one of the most significant trends in the evolution of global tax systems by asking how, within less than half a century, the value-added tax (VAT) has risen from relative obscurity to become one of the world's most dominant revenue instruments. Despite its significance, very...

This chapter contests the claim made by Murphy and Nagel that the choice of tax base is of only instrumental significance to economic justice (The Myth of Ownership (OUP, 2002, 8. 98)). We agree with Murphy and Nagel that what ultimately justifies taxation is its contribution to just outcomes,...

The OECD International VAT/GST guidelines (OECD Guidelines) are the most significant global attempt to coordinate place of taxation rules for cross‑border supplies of services and intangibles so that the final consumption of such supplies are effectively taxed on a destination basis. However,...