In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

This paper examines the pre- and post-tax returns to Canadian and US executives who receive backdated stock options (that appear to be at-the-money options) compared to currently-dated in-the-money options. We begin by comparing the Black-Scholes value of backdated at-the-money options to...

Section 156 of the Income Tax Act 1976 permits exporters to make certain deductions when calculating their assessable income. In order to qualify for an export incentive deduction the court in Preece v Commissioner of Inland Revenue (1981) 4 TRNZ 379 held that the applicant must be the owner of...

In this article, the authors examine the present administrative system for the earned income tax credit (EITC) especially the refinements resulting from enactment of the Omnibus Budget Reconciliation Act of 1990 (OBRA). After describing the problems created by the complexities of the new EITC,...

The deduction for qualified residence interest (QRI) is the second largest individual tax expenditure, after the exclusion for employer provided health insurance. While homeownership has long been viewed as a social good, the QRI deduction has faced criticism. Commentators have argued that it is...

The complexity of the income tax is an unending source of complaint, and compliance costs are estimated to be very large. Yet most recognize that some degree of complexity is necessary if income is to be measured accurately. This article presents a framework for analyzing the value of greater...

The proper tax treatment of interest expense has been a subject of disagreement since the inception of the modern income tax in the early twentieth century. On one view, the purpose of the financing transaction dictates the tax treatment of interest so that interest paid on borrowing used to...

This contribution deals with the question whether - from the perspective of cross-border neutrality - tax reductions for personal circumstances should be applied only by the country of residence, or whether they should also be granted by the source country, and, if so, how such tax reductions...

The IRS has an uneasy relationship with tax return preparers. Preparers may ease the tax filing process and improve take-up of benefits like the earned income tax credit (EITC); however, preparers also profit from financial products sold in connection with tax preparation that have been viewed...