When it comes to the tax world, the starting point is that international tax law does not currently give any special status to a meta realm as a distinct jurisdiction. The metaverse is not a term of art recognised by tax law. However, what we are likely to see is a change in business models and...

Digital tokens, or crypto assets, are digital financial assets based on distributed ledger technology. They come in a considerable variety of forms and have been used in a large number of different ways. Yet, relatively few tax laws of any jurisdiction mention digital tokens specifically. It is...

Tax authorities around the world have stepped-up enforcement activities on the taxation of digital tokens and begun providing more guidance to taxpayers. However, the relative novelty of the field means that there is likely to be considerable uncertainty as to the correct tax treatment, both on...

Brief in support of Joshua Jarrett’s petition to the IRS seeking to establish that his cryptocurrency “staking rewards” are not taxable income until sold. Upon the IRS’s failure to respond to or rule on this petition, suit was filed in Joshua Jarrett v. United States, No. 3:21-cv-00419...

Defined value clauses used to value nonmarketable family limited partnership (FLP) interests create valuation distortions and other public policy issues. This paper describes these abuses and proposes the employment of restrictions similar to those applied to pecuniary formula marital deduction...

At a superficial glance, Internal Revenue Code Section 892 appears to favor sovereign wealth funds (SWFs) over foreign private investors by exempting the former from tax on a significant range of US investments. This has recently led to calls for its abolition. Several authors, however, have...

Successive governments have promised to reduce business red tape, whilst doing nothing about it. In fact, with regard to the tax system, ever-greater numbers of taxes and ever-greater complexity have increased burdens on businesses by turning firms into unpaid tax collectors.Research into the...

Die letzte kleine Reform der deutschen Grundsteuer liegt über dreißig Jahre zurück. Spätestens mit der deutschen Einheit sind die systematischen und administrativen Schwächen dieser Gemeindesteuer derart in den Vordergrund getreten, dass ihre grundlegende Reform überfällig geworden ist....

Goods and services tax (GST) is a broad based and a single comprehensive tax levied at every stage of the production and distribution chain with applicable set-off in respect of the tax remitted at previous stages. It is basically a tax on final consumption integrates the union excise duties,...

This work examines in depth the hypotheses explaining the tax capacity of regional governments, also determining their tax effort and explanatory factors. The study is done for the Spanish regions, using different techniques which have rarely been applied in this area. The results show that...