It is usually a straightforward tax question: is an advance of capital to a business debt or equity? But in some cases the question gets harder to answer, mostly because of the tangled multi-factor test we use. Long ago most tax practitioners gave up trying to clean up the process of answering...

Sovereign democratic nations make tax laws that reflect the needs and preferences of their citizens. This straightforward proposition suggests that tax laws may differ from country to country, and they do. Taxpayers may exploit some of these differences to their advantage. Over the past...