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...

This book explores one of the most significant trends in the evolution of global tax systems by asking how, within less than half a century, the value-added tax (VAT) has risen from relative obscurity to become one of the world's most dominant revenue instruments. Despite its significance, very...

This chapter contests the claim made by Murphy and Nagel that the choice of tax base is of only instrumental significance to economic justice (The Myth of Ownership (OUP, 2002, 8. 98)). We agree with Murphy and Nagel that what ultimately justifies taxation is its contribution to just outcomes,...

In addition to funding government and redistributing income, a redistributive tax-and-transfer system, and a progressive income tax in particular, provides insurance against the risk of uncertain future income. By providing for high taxes for high incomes, and low taxes, exemptions, and...

U.S.-based multinational corporations are calling for a tax holiday that would allow them to repatriate their foreign earnings at little tax cost. With over $1 trillion in earnings trapped offshore and untaxed by the U.S., these corporations characterize the proposed repatriation holiday as a...

On 1 July 2009, in response to the 2009/2010 federal Budget, s23AG of the Income Tax Assessment Act 1936 (Cth) (ITAA36) was amended to include a new s23(1AA). This amendment has the effect of disallowing certain Australia resident individual taxpayers, who are engaged for more than 90 days of...

The Tax Administration Act 1994 contains a penalty for taking an abusive tax position. This 'civil' penalty is 100 percent of the relevant tax shortfall. In other jurisdictions, similar penalties are treated as criminal and the expected protections apply. The abusive tax position penalty was...

In the 1980s the Australian Personal Income Tax was highly progressive and family payments were universal. The system ranked well in terms of gender equity and female labour supply incentives. During the Howard years the progressivity of the rate scale declined dramatically despite rising...

Cross-border intra-group debt represents a significant proportion of total global monetary flows. Responding to tax base erosion from related party interest deductions, countries have introduced domestic rules against “interest stripping” but the heterogeneity of these rules leads to double...