This paper investigates the effect at the bank and industry level of a 1996 tax law change allowing commercial banks to elect S-corporation status. By the end of 2007, roughly one in three commercial banks had either opted for or converted to the S-corporation form of organization. Our study...

After specifying the legal nature of tax law as a coercive power application and as a public authority expression, this article examines the way economic tax theories acknowledge these essential fiscal dimensions. Indeed, tax constraint induces a behaviour modification, so that the legal rules...

The article deals with the cost of tax compliance which arises for taxpayers from tax complexity and the constant changes in tax legislation. A socially responsible institution for the fiscal aggression is the Financial Administration of the Republic of Slovenia, as its powers and...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

On 30 September 2017, the United Kingdom implemented a powerful new investigative tool known as an “unexplained wealth order” in its Criminal Finances Act 2017. On 7-8 November 2017, London hosted the Fifth OECD Forum on Tax and Crime. Against this background, as well as other recent...

We propose a game-theoretic investigation to capture the interplay between the behavior of tax consultants, taxpayers, and the tax authority in a setting of tax complexity. Our purpose is to provide answers to two research questions: Which aspects of the strategic interaction between the players...

This paper sets out the text and translations of over sixty of the world's general anti-avoidance rules. General anti-avoidance rules are found in taxation statutes. Known as “GAARs”, they are perhaps the most intractable of all statutory provisions, challenging alike to policy-makers,...