Should Treasury regulations and IRS guidance documents be eligible for pre-enforcement judicial review? The D.C. Circuit's 2015 decision in Florida Bankers Association v. Treasury puts its interpretation of the Anti-Injunction Act at odds with both general administrative law norms in favor of...

The subject of taxpayer rights is receiving increasing attention worldwide. Tax scholars, practitioners, and administrators are grappling with the challenges of delivering on the promise of taxpayer rights, the benefits of success, and the price of failure. Nevertheless, a fundamental question...

As the economy becomes global and ICT-reliant, approaches practiced in enterprise software product development and enterprise resource planning (ERP) system implementation must cope with increasingly complex situations induced by contemporary supply chain and regulations. Compliance with...

In a world where the grocery store may be more powerful than the government and corporations are the governors rather than the governed, the notion of corporations being only private actors is slowly evaporating. Gone is the view that corporations can focus exclusively on maximizing shareholder...

The U.S. has always had two distinctly different methods for taxing business profits. The method that applies in any given case has always depended on the tax classification assigned to the firm. However, there has never been a satisfactory way to determine a firm's tax classification because...

This article investigates the potential for regulatory competition within the legal framework of the Eurasian Economic Union (EEU). By comparing the legal structures of the EU and the EEU, this article outlines the ways in which regulatory competition is embedded in each of the legal frameworks...

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...

The past few years have seen the rise of a new model of production and consumption of goods and services, often referred to as the “sharing economy.” Fueled by startups such as Uber and Airbnb, sharing enables individuals to obtain rides, accommodations, and other goods and services from...

Since 1980, the United States has taxed U.S. real property gains of foreign investors. A nonresident must pay tax on the capital gain from the sale of U.S. real property or rights in U.S. real property, as well as on the sale of shares in non-publicly held domestic corporations that hold...

This book chapter is part of an analysis of European Community (EC) law as it may apply to taxpayers who are resident or nationals of countries that are not EC members (third states), specifically in the field of tax law. The chapter addresses the relation between South African and EC tax law....