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...

For over a century, politicians, government officials and scholars in the United States have debated whether corporate tax returns, which are currently subject to broad tax privacy protections, should be publicly accessible. The ongoing global discussion of base erosion and profit shifting by...

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...

Each year, the government loses hundreds of billions of dollars in tax revenue due to underreporting by individual taxpayers. According to standard deterrence theory, policymakers should be able to reduce tax evasion by increasing tax penalties, raising the audit rate, or some combination of the...

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...

Credit risk may be warehoused by choice, or because of limited hedging possibilities. Credit risk warehousing increases capital requirements and leaves open risk. Open risk must be priced in the physical measure, rather than the risk neutral measure, and implies profits and losses. Furthermore...

A discussion by a panel of experts, including Sir Ivor Richardson, of topical tax issues, including: (1) the scope for taxpayers to seek judicial review by the courts of the exercise of the Commissioner of Inland Revenue's powers, with particular reference to information gathering by the CIR at...

This paper argues that there is too great a reliance placed on anti-avoidance provisions, discretions reposed in the revenue, and judicially developed doctrines as a means of countering tax avoidance. In view of the difficulties in defining and countering tax avoidance, it is suggested that...

This paper describes the relevance to lawyers and law students of the concept of income for tax purposes and tax policy. Three reasons are given for law practitioners to have an understanding of the policies underlying tax legislation: the complexity of the legislation; the fact that it can...

Section 108 of the Land and Income Tax Act 1954 was of great practical significance as a general anti-avoidance tax section, but was plagued by difficulties of interpretation and application. In this article, Sir Ivor Richardson reviews the development of section 108, the reasons for recasting...