This Essay proposes a conceptual framework for the regulation of transactions involving cryptocurrencies. Cryptocurrencies offer tremendous opportunities for innovation and development but are also uniquely suited to facilitate illicit behavior. The regulatory framework suggested herein is...

Every spring, the federal government appears to deliver an abundance of announcements that describe criminal convictions and civil injunctions involving taxpayers who have been accused of committing tax fraud. Commentators have occasionally suggested that the government announces a large number...

This National Report was prepared for a conference titled Tax Secrecy and Tax Transparency – The Relevance of Confidentiality in Tax Law, which took place in July 2012 in Rust, Austria and was co-hosted by the Institute for Austrian and International Tax Law at the Vienna University of...

Portuguese abstract: Este livro fornece uma visão abrangente da forma como o Tribunal de Justiça da União Europeia aplica a análise da proporcionalidade, especialmente no que diz respeito à avaliação da compatibilidade das regras de tributação direta nacionais com as liberdades...

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...

This article deals with the decision taken by the Court of Justice of the European Union in Groupe Steria SCA (Case C-386/14), in respect of which the Second Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 2 September 2015, following the Opinion of Advocate...

This article deals with the decision taken by the Court of Justice of the European Union in Miljoen and others (Joined Cases C-10/14, C-14/14 and C-17/14), in respect of which the Third Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 17 September 2015,...

In this article, the author makes a critical exam of a decision of the Portuguese Supreme Administrative Court which interprets the prohibition of discriminatory treatment as enshrined in tax treaties and assesses whether nationals of another State may access, in the same conditions, tax...