Taking Singapore as an example, this article lays out a series of tests for determining whether gains arising from the disposal of cryptocurrencies are trade or business income, “all other income” or capital gains. It also considers the possibility of a presumption that individuals engaging...

Among government agencies, the IRS likely has the surest legal claim to the most information about the most Americans:their hobbies, religious affiliations, reading activities, travel, and medical information are all potentially tax relevant. Privacy scholars have studied the arrival of Big...

A controversial new financing phenomenon has recently emerged. New “income share agreements” (“ISAs”) enable an individual to raise funds by pledging a percentage of her future earnings to investors for a certain number of years. These contracts, which have been offered by entities such...

Due to advances in technology like mobile applications and online platforms, millions of American workers now earn income through “gig” work, which allows them the flexibility to set their own hours and choose which jobs to take. To the surprise of many gig workers, the tax law considers...

In this Article, we investigate the tax issues and challenges facing Uber and Lyft drivers by studying their online interactions in three internet discussion forums. Using descriptive statistics and content analysis, we examine (1) the substantive tax concerns facing forum participants, (2) how...

This Essay proposes a conceptual framework for the regulation of transactions involving cryptocurrencies. Cryptocurrencies offer tremendous opportunities for innovation and development but are also uniquely suited to facilitate illicit behavior. The regulatory framework suggested herein is...

This is the tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates multiple provisions of international human rights instruments that have been signed, or signed and ratified, by the United States. The rights in question...

This working paper is a forthcoming chapter in the Oxford Handbook of Law and Economics, edited by Francesco Parisi. It provides a brief overview of economic issues in tax law, including distribution and efficiency in general, the role of administrative and political economy concerns in an...

An annual wealth tax, a mark-to-market income tax, and a retrospective capital gains tax are three approaches to capital taxation that yield roughly equivalent outcomes under certain conditions. The three approaches differ starkly, however, in their exposure to uncertainty of various types. This...

This article aims to analyse the multilateral action and instruments that have been and are being developed by the Organization for Economic Cooperation and Development (“OECD”) to enhance transparency and exchange of information and the Base Erosion Profit Shifting (“BEPS”) Project in...