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[This testimony was delivered on December 8, 2021, to the House Committee on Ways and Means, Subcommittee on Oversight, as part of a hearing on "The Pandora Papers and Hidden Wealth."]The US is the world’s leading investment destination for offshore wealth. Our laws enable foreigners—through...
Persistent link: https://www.econbiz.de/10013307096
The Internal Revenue Code is riddled with features that allow U.S. taxpayers to reduce their federal tax liability by operating through tax haven companies. Some of these provisions are historic anomalies. Others are better understood as inadvertent loopholes than considered legislative grace....
Persistent link: https://www.econbiz.de/10014190764
Persistent link: https://www.econbiz.de/10013130328
This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...
Persistent link: https://www.econbiz.de/10013065662
Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International's corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages,...
Persistent link: https://www.econbiz.de/10012963094
This paper revisits earlier studies on the determinants of tax amnesties. The novel findings are (i) amnesties are more likely to be declared during fiscal stress periods, and (ii) political factors significantly affect the introduction and timing of amnesties. In particular, the paper...
Persistent link: https://www.econbiz.de/10012779151
This article discusses the task of identifying controlled transactions under review by the Commissioner of the Internal Revenue Service. In particular, it aims to alert courts as to the necessary role of contractual interpretation law in determining the true nature of such controlled transactions
Persistent link: https://www.econbiz.de/10013004029
This National Report was prepared for the 2014 Annual Congress of the European Association of Tax Law Professors, which took place in May 2014 at Koç University, Istanbul, Turkey. This National Report discusses administrative and legal mechanisms, especially the Foreign Account Tax Compliance...
Persistent link: https://www.econbiz.de/10013049101
This National Report was prepared for a conference titled Tax Secrecy and Tax Transparency – The Relevance of Confidentiality in Tax Law, which took place in July 2012 in Rust, Austria and was co-hosted by the Institute for Austrian and International Tax Law at the Vienna University of...
Persistent link: https://www.econbiz.de/10013062343
This paper analyzes the sources of heterogeneity in legal tax avoidance strategies across individuals. Three conditions … are required for a taxpayer to participate in tax avoidance: incentive, access, and awareness. Using rich Swedish … explaining participation in legal tax avoidance substantially differ from those explaining participation in illegal tax evasion …
Persistent link: https://www.econbiz.de/10009736758