In the early twentieth century, the taxation of modern business corporations became increasingly important to the development of American democracy. During that time, governments at all levels began to view business corporations not only as sources of badly needed public revenue, but also as...

In this report, Fleming, Peroni, and Shay analyze the effects of including a final, low-rate minimum tax on U.S. multinational corporations in a territorial system. They continue to prefer a real worldwide international tax system, but see a final, low-rate minimum tax as a second-best measure...

Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore...

In this paper we use audited corporate tax disclosures relating to a tax holiday on repatriated earnings created by the American Jobs Creation Act of 2004 to examine the return on lobbying. We find firms lobbying for this provision have a return in excess of $220 for every $1 spent on lobbying,...

In this Article, three methods of exiting are partnership are examined. Each exit strategy offers significant tax advantages to the nonexiting partners. In two of the exit strategies, well-known defects in Subchapter K are exploited, and I conclude that the strategies cannot be attacked...

Since 2010, international tax policymakers have proposed a variety of minimum taxes on excess returns, but every proposal has defined excess returns differently. This Article asks what excess returns are supposed to represent – and concludes that the answer is very different from what...

Blockchain technology, perhaps the most revolutionary invention of the 21st century, was popularized by introducing the world's first cryptocurrency 'Bitcoin.' However, despite many purported advantages offered by cryptocurrencies, they eluded mass adoption due to their extreme volatility. This...

The novel coronavirus demands untold amounts of public spending even as it has destroyed untold amounts of economic value, yet the fortunes of some taxpayers will multiply in the process. The authors consider proposals to rebuild revenue coffers using excess profits taxes and argue that, owing...

This Study contains the final version of the document elaborated by the IBFD Task Force on the Digital Economy as a submission to the European Commission in the framework of its 2021 Public Consultation on the possible introduction of an EU digital levy. Based on a reconstruction of the...

The IRS ended a long-time practice of requiring most nonprofits to disclose substantial donor names and addresses on the nonprofit annual tax return. It is largely seen as a battle over campaign finance rather than tax enforcement. Two of the nonprofits involved, social welfare organizations and...