This paper puts in evidence that Shavell idea according to which we can have at least a party that takes an efficient level of activity, in a situation of bilateral accident, with the usual tort rules, is wrong. The most important example that there is this mistake is that authors state that a...

The latest wave in tax shelter reform is the recent codification of the so-called “economic substance doctrine” and the accompanying strict liability penalty for violations of the doctrine. The new strict liability penalty has been criticized by tax scholars and practitioners for being...

Section' 461(h), dealing with the treatment of liabilities by accrual-method taxpayers, was enacted in 1984, in response to the failure of the Internal Revenue Code to recognize time-value-of-money concepts in the tax laws. Prior to the enactment of § 461(h), an accrual-method taxpayer could...

The tax treatment of personal injury damages has been largely ignored in Canada, despite questionable authority for the generally accepted position that they are not taxable. Courts have reasoned that personal injury damages are not subject to tax because these awards replace lost human capital....

The authors use a unique data set of federal tax returns to analyze usage and participation patterns of the Earned Income Tax Credit (EITC) over the period 1989–2006. The authors find that most EITC recipients claimed the EITC for short periods, 61% for 1 or 2 years. Over the period examined,...