Tax law is often uncertain. In particular, the use of tax shelters tends to be in the "grey area" between illegal tax evasion and legal tax avoidance. In this paper I show that uncertainty in tax law can help achieve higher efficiency than allowing or disallowing a tax shelter with certainty....

We exploit the 2017 US tax reform to learn about the tax-competitiveness of US multinational corporations (MNCs) relative to their international peers. Matching on the propensity score, we compare pairs of similar US and European firms listed on the S&P500 or StoxxEurope600 in a...

This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

To reduce tax evasion, most nations use either common law anti-abuse doctrines, statutes, administrative rules, or a combination of the three. None of them have worked fully, and, given human nature, it is unlikely that anything will ever work fully. However, as this Article will outline, some...

In all countries that use the individual as the basic unit of taxation, tax policy makers must contend with the problem of spousal income splitting and the dilemma it poses for gender equality. On the one hand income splitting opens a back door to joint taxation of couples, with its troubling...

Theory and recent empirical literature suggest that social and professional connections may influence corporate policy. However, inference may be biased by the possibility that firms who share peers also share unobserved characteristics that are correlated with observed policy. Using a novel...

Among the possible responses to the problem of avoidance a country may enact a general anti-avoidance rule, couched in terms wide enough to frustrate tax planning strategies that have yet to be invented. One difficulty of general anti-avoidance rules is that they cannot be interpreted as undoing...

In his Technical Information Bulletin of February 1990 the Commissioner of Inland Revenue issued a policy statement on Section 99 of the New Zealand Income Tax Act 1976. Section 99 is a general anti-avoidance provision that voids for income tax purposes arrangements that have the purpose or...

The fallout from the “Panama Papers” scandal leaves many questions unanswered, including: How did U.S. taxpayers get to the Panamanian law firm of Mossack Fonseca? And what were the ethical responsibilities of the individuals (particularly U.S. lawyers) who connected these U.S. clients with...

Without an express consent and authorization from the customer in relation to a FATCA disclosure, Chinese Foreign Financial Institutions' ("FFIs") compliance with FATCA would be in conflict with relevant domestic laws. However, under Chinese laws, Chinese authorities have broad powers to obtain...