This Essay proposes a conceptual framework for the regulation of transactions involving cryptocurrencies. Cryptocurrencies offer tremendous opportunities for innovation and development but are also uniquely suited to facilitate illicit behavior. The regulatory framework suggested herein is...

The United States is currently trying to manage a fast-moving public health crisis due to the coronavirus outbreak (COVID-19). The economic and financial ramifications of the outbreak are serious. This Working Paper discusses these ramifications and identifies three interrelated but potentially...

Annually, the U.S. government collects nearly $3 trillion of income and employment taxes. With respect to these collections, Form 1040 (U.S. Individual Income Tax Return) seeks to ensure taxpayer accuracy. Currently, two sets of players dominate the Form 1040 preparation and submission process:...

This Comment evaluates four recent proposals to reform tax laws affecting the financial industry. After introducing the proposals, the author provides a theoretical framework for evaluating them and then relies on this framework to explore the benefits and drawbacks of each. Ultimately, the...

In the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA), Congress included a provision requiring bankruptcy courts evaluating individual debtors' financial circumstances to utilize certain monthly expense standards developed by the Internal Revenue Service for assessing...

In contrast to financial arbitrage, which causes prices of economically equivalent transactions to converge in the direction of one price, regulatory arbitrage does not lead to such price convergence. In contrast, regulatory arbitrage tends to produce two different prices for economically...

The European Union’s new Foreign Subsidies Regulation will lead to particular challenges in the tax domain. While the final version of the FSR now contains clear links to state aid, the differences are all the more noticeable. Third country tax measures that benefit group financing or equity...

This article discusses the proposal to modify regulations that determine a debt instrument's issue price whenever there is an exchange of an instrument involving publicly traded property. Under both proposed and current regulation section 1.1273-2, the issue price of an instrument received in an...

The latest empirical results of the size of the shadow economy in 18 OECD countries are presented, using the currency demand approach to calculate the shadow economy over time. The results indicate a strong increase in the size of the shadow economy, over the period 1960 to 1998 and for 15 of...

The latest empirical results of the size of the shadow economy in 18 OECD countries are presented, using the currency demand approach to calculate the shadow economy over time. The results indicate a strong increase in the size of the shadow economy, over the period 1960 to 1998 and for 15 of...