This past July 1 marked a Tax Shelter anniversary. On that date twelve years ago, the IRS issued Notice 2003-47, challenging the deferral of income by corporate executives using the so-called ECS, an acronym variously interpreted to mean the Executive Compensation Solution, the Executive...

Based on a traditional legal dogmatic method, valid law is deduced with respect to general anti-abuse rules (GAARs) in Danish tax law. Accordingly, first it is discussed whether a court-developed general anti-avoidance doctrine can be considered to exist. Subsequently, the provision containing...

This article considers the application of BEPS Action 2 to trust-based hybrid mismatches. It demonstrates that the recommendations in the BEPS Action 2 Report do not address trust mismatches in a sensible and systematic way. Trust mismatches should be the subject of further work to develop rules...

Government attacks on abusive tax shelters often assume one of two forms. On the one hand, the Executive Branch brings actions that rest, in part, on broad judicial doctrines. One such doctrine, for example, requires that potentially abusive transactions demonstrate economic substance. On the...

The thesis puts at the spotlight the issue of having state aid which is incompatible with the EU law, in so far as it stems from a selective advantage granted to multinational enterprises through the means of advance pricing arrangements.It is submitted that advance pricing arrangements have a...

This paper studies the evolution of modern Swedish wealth taxation since its introduction in 1911 until it was abolished in 2007. It offers a thorough description of the rules concerning valuation of assets, deductions/exemptions and tax schedules to characterize effective wealth tax schedules...

We examine whether worker representation on corporate boards results in improved monitoring or payroll maximization. Several economic theories predict that worker representatives would use control and voting rights in the boardroom to transform firm assets into private benefits and increased...

This paper studies the evolution of the modern Swedish inheritance taxation from its introduction in 1885 to its abolishment in 2004. Our contribution is twofold. First, we compute annual effective inheritance tax rates for differently sized bequests and different types of inherited assets...

Using a large panel dataset on worldwide operations of multinational firms, this paper studies one of the most advocated anti-tax-avoidance measures: Controlled Foreign Corporation rules. By including income of foreign low-tax subsidiaries in the domestic tax base, these rules create incentives...

This paper studies the evolution of the modern Swedish inheritance taxation from its introduction in 1885 to its abolishment in 2004. A thorough description is offered of the basic principles of the tax, including underlying ideas and ambitions, tax schedules, and rules concerning valuation of...