The taxation of high-income earners is of importance to every country and is the subject of a considerable amount of recent academic research. Such high-income earners contribute substantial amounts of tax and generate signifi cant positive spillovers, but are also highly mobile: a 1% increase...

The basic deterrence model of tax evasion is described, its main predictions are derived and limitations and flexibility are outlined. Further, the model is interpreted in light of some key institutional features characterising tax enforcement in OECD countries. Throughout the survey, findings...

This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

Governments attack tax avoidance in a number of ways. Statutory anti-avoidance rules are one means. Such rules come in two forms: specific and general. General rules potentially apply to any kind of transaction that may result in tax avoidance. Section 99 of the New Zealand income Tax Act 1976...

Section 99 of the Income Tax Act 1976 provides that agreements purporting to alter the incidence of tax shall be void against the Commissioner for tax purposes. Tayles & Tayles v Commissioner of Inland Revenue [1982] 2 NZLR 726 involved a complex arrangement of trusts and partnerships. The...

The objector in Halliwell v. Commissioner of Inland Revenue 1 NZLR 363 arranged his affairs in order to minimise his tax liability. The court held that if deductions satisfy section 111 of the Land and Income Tax Act 1954 (largely the same as section 104 of the Income Tax Act 1976) they will be...

The taxation of high-income earners is of importance to every country and is the subject of a considerable amount of recent academic research. Such high-income earners contribute substantial amounts of tax and generate significant positive spillovers, but are also highly mobile: a 1% increase in...

Although nonqualified deferred compensation plans lack explicit tax preferences afforded qualified plans, it is well understood that nonqualified deferred compensation results in a joint tax advantage when employers earn a higher after‐tax return on deferred sums than employees could do on...

This article was contributed to the special isse of Osgoode Hall Law Journal Volume 52, Issue 2 (Summer 2015) "Tax Policy for a Better Tomorrow: Intersectoral and Multidisciplinary Connections, a Workshop in Honour of Neil Brooks," Guest Editor: Tim Edgar, Thaddeus Hwong & Jinyan Li.The purpose...

We examine whether “kiddie tax” legislation in Canada, effective as of 2000, deters income splitting between parents and minor children by taxing at the top marginal rate certain types of non-labour income received by children. OLS estimates based on cross-province and time-series data...