This paper is part of a comparative analysis of the distribution of the taxing authority among different levels of governments throughout a broad range of nations. Switzerland being a mere Confederation in the technical sense of the word for centuries before becoming a federal state, it may well...

One of the central issues in comparative law and political economy is whether the forces of globalization will result in the convergence of public policies across countries. Noting in particular that taxes collected still cover a considerable range across industrialized countries - from a low of...

A recent Sixth Circuit case challenged the validity under the Commerce Clause of the U.S. Constitution of an Ohio income tax credit. Although the Supreme Court overruled the decision on May 15, holding that the plaintiffs in the case did not have standing to challenge the incentives in federal...

This article recommends allowing a lessor and a lessee to decide between themselves which party will be entitled to the tax benefit associated with the ownership of the leased property. It describes why the current linkage of tax benefits to property ownership is economically inefficient and...

The ability of the Internal Revenue Service (IRS) to both collect the tax and enforce the initial determination of tax liability in a neutral and fair manner has been compromised by a February 2011 pronouncement issued by the Department of Justice (“Justice”) stating that the President and...

Retrospective amendments have always been a bone of contention in taxation laws. Sometimes to cure the defects pointed out by courts in the fiscal legislation and sometimes (by being accompanied by validation laws) to take away vested rights of the citizens, retrospective amendments are not...

Property owners who make charitable gifts of perpetual conservation easements are eligible to claim federal charitable income tax deductions. Through this tax-incentive program the public is investing billions of dollars in easements encumbering millions of acres nationwide. In response to...

For more than fifty years, taxpayers have been able to claim a federal charitable income tax deduction under Internal Revenue Code § 170(h) for the donation of a conservation easement or a façade easement. For just as long, the deduction has been subject to abuse, including valuation abuse....

Canadian National Report prepared for the Vienna University of Economics and Business, Conference on tax secrecy and transparency, Rust, Austria, July, 2012. The aim of the project is to assess how different countries regard the treatment of tax information and tax secrecy. Topics include the...