This paper examines the consequences of allowing a non-profit organization to form a joint venture with a for-profit organization. Three tax regimes are considered: prohibiting all such joint ventures; allowing all such joint ventures; and restricting joint ventures between non-profit and...

This paper examines the effects of banning contingent fees for tax return preparation services. It develops a principal-agent model in which a taxpayer contracts with a tax practitioner to attempt to resolve tax law uncertainty. The contract must induce the practitioner to do research and take...

This paper examines the properties of the effective tax rate (ETR) as a measure of managerial tax planning effectiveness using a principal-agent model. ETR is calculated as Tax Expense (computed pursuant to SFAS No. 109) divided by Income Before Taxes. The changes in ETR due to the agent's...

This paper develops a model of dynamic tax planning in which the implementation of a tax plan involves exercising the option regarding an irreversible investment or financing structure choice. The model is applied to a common estate freeze tax plan. Undertaking an estate freeze requires a...

This paper uses a strategic tax compliance model to examine taxpayer reporting and tax authority audit strategies in an international setting with two tax authorities. The setting features both information asymmetry between the taxpayer and the tax authorities and tax law ambiguity. The latter...

The non-profit sector in the United States owns investment assets of about $1 trillion. Nearly half of these assets are owned by private foundations. The tax law requires that private foundations spend at least five percent of their assets each year on charitable purposes. Despite this minimum...

This paper examines the effects of banning contingent fees for tax return preparation services. It develops a principal-agent model in which a taxpayer contracts with a tax practitioner to attempt to resolve tax law uncertainty. The contract must induce the practitioner to do research and take...

We investigate the use of bilateral advance pricing agreements (BAPAs) to resolve transfer pricing disputes between a taxpayer and two tax authorities. BAPAs are designed to protect firms from double taxation while reducing expected compliance costs (audits costs plus BAPA implementation costs)....

The taxation of multinational income is the subject of important policy debates. For example, the recent Pillar One proposal by the Organisation for Economic Development and Cooperation (OECD) would shift taxing rights from countries in which value is created to countries where it is realized....