Abuse is one of the core issues in EU direct tax matters. Much has been written over the past years. The discussion on the interpretation and application of the different elements of the anti-abuse clauses appears to be settling. However, an equally fascinating discussion appears to be emerging:...

Each year, the government loses hundreds of billions of dollars in tax revenue due to underreporting by individual taxpayers. According to standard deterrence theory, policymakers should be able to reduce tax evasion by increasing tax penalties, raising the audit rate, or some combination of the...

In the past year, a number of new financial transactions (such as the Fantex, Upstart and Pave transactions) have emerged that allow individuals to raise funds by offering a percentage interest in their future earnings. Unlike traditional lending arrangements, these structures essentially enable...

In this report, the first in a series of reports on EU state aid, Mason provides background on state aid law as it applies to income taxes, including the legal standard, recovery mechanism, and case selection by the Commission

The overall aim of this article is to analyze the taxpayers' rights to confidentiality and privacy in exchange of information including the new global standard of automatic exchange of information. The first section will analyze the state of the art regarding the right to privacy and...

In 1992, the Treasury Department proposed a comprehensive business income tax, or CBIT, as a reform option for the taxation of business income. In Treasury's proposal, all taxes on business income (including income of sole proprietorships) would be replaced by a flat, entity-level tax. Interest...

This paper applies the economic theories of fiscal federalism and jurisdictional competition to the question whether the juridical presumption favoring decentralization of authority manifested in the European Union's subsidiarity principle has been rebutted in the case the Code of Conduct on...

This Handbook entry presents a conceptual, normative overview of the subject of taxation. It emphasizes the relationships among the main functions of taxation—notably, raising revenue, redistributing income, and correcting externalities—and the mapping between these functions and various...

In this report, I argue that the inversion situation is more nuanced, complex, and ambiguous than Edward D. Kleinbard acknowledges, and I challenge Kleinbard's claim that U.S. multinationals are on a tax par with their foreign competitors