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...

This paper argues that there is too great a reliance placed on anti-avoidance provisions, discretions reposed in the revenue, and judicially developed doctrines as a means of countering tax avoidance. In view of the difficulties in defining and countering tax avoidance, it is suggested that...

The article assesses the impact of a Common Corporate Tax Base (CCTB) as promoted by the European Commission and the related Working Groups on the effective tax burdens of companies in all 27 EU member states. The results shall help to evaluate the economic consequences of introducing a...

This paper comprises a transcript of the oral addresses and discussion at a colloquium that compared the general anti-avoidance rule of income tax law with the civil law doctrine of Rechtsmissbrauch (abuse of law) and similar doctrines in eight jurisdictions: Germany, Croatia, New Zealand,...

This paper provides a general equilibrium model of income tax evasion. As functions of the share of income reported, the paper contributes an analytic derivation of the tax elasticity of taxable income, the welfare cost of the tax, and government revenue as a percent of output. It shows how an...

Harmonisierung der heterogenen Unternehmensteuern in Europa? Der vorliegende Pforzheimer Beitrag möchte für Europa einen Mittelweg der Harmonisierung der Besteuerung von Unternehmensgewinnen aufzeigen. Es geht um eine gemeinsame körperschaftsteuerliche Bemessungsgrundlage und ihre steuer- und...

Should we see major tax reform, taxpayers will clamor for guidance from Treasury and the Internal Revenue Service ('IRS') regarding new provisions, as they did after passage of the Tax Reform Act of 1986 ('1986 Act'). Indeed, the greater the degree of reform, the greater the need for guidance....

This Article addresses the legal consequences a taxpayer should consider when deciding whether to comply with the basic requirements of the federal income tax laws. A taxpayer considering noncompliance should consider the government's authority to assert criminal liability, impose civil tax...

This Article analyzes the meaning of probability statements in tax law and in scholarship addressing civil tax penalties. Specifically, the Article draws on economics and the philosophy of mathematics to argue that because tax law is substantively uncertain, some probability statements in tax...