Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...

Against a backdrop of ongoing angst regarding release of tax guidance, an important idea has surfaced in the tax compliance literature. Prominent tax compliance scholars have argued that the strategic use of tax law uncertainty may cause taxpayers to report higher tax liability. While these...

This article, which is based on the inaugral address given at the IBFD Tax Lecture Series in Beijing, China, examines the basic foundations and nature of income tax law before going on to offer a unifying theory of taxation law. Income tax law is notoriously complex for a range of reasons. One...

Prevailing accounts of the efficiency of subsidies for the nonprofit sector presume that the only alternative source of public goods is a single sovereign, controlled by a single median voter. Tiebout sorting, however, also provides citizens with alternative bundles of public goods. When these...

In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

In this article we tackle a fundamental problem in tax law: the resistance of the core concept of “income” to a coherent definition. It has long been recognized that there is a substantial gap between the formal definition of income adopted in 1955 by the Supreme Court in Commissioner v....

This Estate and Gift Tax Rap column for Tax Notes is an extended discussion of the United States District Court (W.D. Pa.) decision in Estate of Palumbo v. U.S.. In that case, the court upheld a claimed estate tax charitable deduction for amounts passing to charity pursuant to a settlement of a...