This article provides a general overview of various privilege issues that frequently arise in the tax context, with a focus on international tax proceedings. Commonly disputed issues include the attorney-client privilege, work-product doctrine, accountant's privilege, tax practitioner privilege,...

Amid growing globalization, many countries have offered significant tax incentives to attract corporate investment. Prior research studies the role such tax incentives play in firms' location and investment choices. However, we have limited evidence on the role tax enforcement plays in those...

We show that the fiscal authorities of high-tax countries can lack the incentives to combat profit shifting to tax havens. Instead, they have incentives to focus their enforcement efforts on relocating profits booked by multinationals in other high-tax countries, crowding out the enforcement on...

In this paper, we consider tax enforcement policy in the presence of profit shifting towards tax havens. We show that, under separate accounting, tax enforcement levels may be too high due to negative fiscal externalities. In contrast, under formula apportionment, tax enforcement is likely to be...