This article concerns the history of automation in U.S. tax administration and the challenges automation presents to administering the laws consistent with democratic values. The most under-theorized aspect of tax administration is the expansion of automation and its impact on the current tax...

This essay explains how current state government approaches to use-tax enforcement undermine tax morale and taxpayer compliance. This essay further argues that these threats to tax morale and taxpayer compliance will become even more severe as many states are moving toward adopting notice and...

Traditional perceptions of tax exceptionalism from administrative law doctrines and requirements have been predicated at least in part on the importance of the tax code's revenue raising function. Yet, Congress increasingly relies on the IRS to administer government programs that have little to...

Valuation issues have long posed challenges for the U.S. federal tax system. This is not just because of questions about what technique will most accurately value particular types of property. A key problem for tax administration is that taxpayers have an incentive to claim erroneous,...

A common phenomenon in tax administration in developing countries is that tax is collected not according to the rules of law but according to informal agreements between taxpayers and tax collectors. This article offers a novel explanation of this phenomenon in the Chinese context in terms of...

It is well known that the government’s complete failure to enforce a law can nullify that law. But what are the effects of partial enforcement? This Article shows that imperfect enforcement can alter the de facto content of the written law in predictable and beneficial ways. Specifically, in...

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...

A common, though by no means universally-accepted doctrine among practitioners of law and economics is that redistribution is no business of the law. This efficiency-only doctrine is not that redistribution is unworthy as a social objective, but that any given benefit to the poor is attainable...

In this paper we apply conjoint analysis as an empirical method to study the influence of tax labeling and tax earmarking on the perceived tax burden. As reference for the individual behavior we use the model of a rational utility maximizer described by the economic theory. We determine a...

Under current law, all true barter transactions, such as babysitting cooperatives, create taxable income. Although the IRS often fails to catch unreported transactions, lawyers and accountants have an ethical duty to advise clients to report these taxable transactions on their income tax...