This letter to the Treasury and the IRS is in response to Notice 2-43's request for recommendations for the 2-2 Priority Guidance Plan on tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. Many of...

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...

Paying taxes is a cost of doing business. The looters (or public servants, depending on your perspective) must be paid and tax proceeds must be distributed to various groups and individuals, both worthy and unworthy. But tax expense includes more than just the amount of taxes that must be paid....

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...

Technology is revolutionizing our lives. With the touch of a button or a simple voice command, we can instantly order groceries, get directions, or find the nearest sushi restaurant. Sensibly, the private sector has capitalized on these recent innovations to drive up profits. To sell more...

This Article documents a process in which a national tax administration in one jurisdiction, is consciously and systematically assisting taxpayers to avoid taxes in other jurisdictions. The aiding tax administration collects a small amount tax from the aided taxpayers. Such tax is functionally...

The main purpose of this book is to promote the dissemination of the basic notions of taxation from a policy, legal and administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The book sets out current principles of taxation...

The IRS recently announced that its mandatory registration regime for paid tax return preparers, struck down in the Loving decision, would henceforth be offered as a voluntary program. But the authors of this program appear to have forgotten that the US system is perfectly global in reach,...

It is well known that the government’s complete failure to enforce a law can nullify that law. But what are the effects of partial enforcement? This Article shows that imperfect enforcement can alter the de facto content of the written law in predictable and beneficial ways. Specifically, in...

Twenty-five of the nation's leading tax academics, practitioners, journalists, and public intellectuals gathered in Malibu, California on the Friday before President Obama's second inauguration to plead for tax reform. The papers published in this issue of the Pepperdine Law Review provide very...