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...

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...

The tax treatment of transactions under an emissions trading scheme is of critical importance as the taxation system has the potential to either distort or support the scheme. As pointed out in the Australian Government's recent discussion paper, the "Green Paper", the primary tax policy...

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...

The assumption that household income is strongly and positively correlated with a household's real standard of living provides the basis for the joint taxation of families, which has the effect of discriminating against married women as second earners. This paper shows, in the context of a model...

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...

This working paper, explains and evaluates key aspects of Australia's GST (a value added tax), focussing on aspects of the law that are of relevance to a comparative tax law scholars considering how legal and policy design features of VAT/GST laws affect the level of simplicity/complexity of the...

This essay notes that the feminist tax policy theorists have made numerous important contributions to our understanding of tax policy's affect on women's lives and experiences. It argues that in doing so, the extant literature has also prioritized the idea of citizenship rights but has failed to...