This Article analyzes the long-term impact on firm behavior of the repatriation tax holiday of the American Jobs Creation Act of 2004 (AJCA). The approach taken is empirical and based on data collected from the public filings of large U.S.-based multinational corporations. Statistical analysis...

This article proposes a progressive system of mark-to-market taxation.Under the proposal, all public companies, all private companies with $50 million or more of net assets, and all individuals and married couples with $1.6 million of adjusted gross income or $5 million of publicly traded...

The trial of McKesson Canada Corporation v. The Queen commenced in the Tax Court of Canada in Toronto on 17 October 2011 and is expected to take six to seven weeks. This case concerns a related party debt factoring arrangement between McKesson Canada Corporation (McKesson) and McKesson...

In the aftermath of the recent financial crisis, a variety of taxes on financial institutions have been proposed or enacted. These taxes' justifications range from punishing those deemed to have caused or unduly profited from the crisis, to addressing the budgetary costs of the crisis, to better...

We examine whether three tax system characteristics – required book-tax conformity, worldwide versus territorial approach, and perceived strength of enforcement – impact corporate tax avoidance across countries after controlling for firm-specific factors previously shown to be associated...

'The Cain Plan v. the Able Plan' is an empirical analysis of the 9-9-9 plan proposed by Mr. Cain and supported by Mr. Laffer. The author reviews the simplicity of the plan and concludes that the Cain tax plan does not support its intended results. The Cain tax plan has gained traction with the...

This paper argues that the large reduction in corporate tax rates and only gradual widening of tax bases in many countries over the last decades are consistent with tougher international competition for foreign direct investment (FDI). To make this point we develop a model in which governments...

In previous articles, we have argued that European Court of Justice's reliance on nondiscrimination as the basis for its decisions did not (and could not) satisfy commonly accepted tax policy norms, such as fairness, adminstrability, production of desired levels of revenues, avoidance of double...

Ontario's new Harmonized Sales Tax applies to a broader base of consumer purchases than before, but it also removes some of the “hidden” taxes on business inputs. This paper offers a first look at how the change has affected consumer prices and the welfare of Ontario families. While consumer...

Compensation for services, regardless of the form, constitutes income to the recipient. Consequently, the exchange of services by two individuals is treated as income to each. However, there are numerous examples of an exchange of services that the IRS has never sought to tax. The most common...