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...

This is the General Report for the United States on the theme of “Surcharges and Penalties in Tax Law” for the 2015 meeting of the European Association of Tax Law Professors in Milan, Italy. The Report addresses questions relating to the treatment of civil penalties, criminal penalties and...

We assess the business provisions of the 2017 Tax Cuts and Jobs Act, the biggest corporate tax cut in US history. We draw five lessons. First, corporate tax revenue fell by 40 percent due to the lower rate and more generous expensing. Second, firms with larger declines in their effective tax...

Over the years, many OECD countries, including the United States, have identified tax havens as a significant problem, and have acted to limit the ability of their taxpayers to use tax havens to reduce their taxes. The United States has implemented tax regimes, including subpart F and the...

The 2017 Tax Cut and Jobs Act reduced the US corporate tax rate and introduced provisions to curb profit shifting. We combine survey data, tax data, and firm financial statements to study the evolution of the geographical allocation of US firms' profits after the reform. The share of profits...

This paper examines the relation between tax enforcement and financial reporting quality. The government, due to its tax claim on firm profits, is de facto the largest minority shareholder in almost all corporations. Therefore, the government, like other shareholders, has an interest in the...

This article evaluates recent state cases upholding a retroactive amendment of a tax statute that reversed a judicial interpretation of the predecessor statute. Practitioners have criticized these cases because the seeming length of the statute's retroactivity has typically been lengthy. The...

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

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...