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 role of tax incentives in charitable giving has seen considerable attention. Yet, attention is limited to direct tax incentives, such as tax deductibility. Whether and how taxing household savings affects charitable giving is largely unexplored. While theory suggests a link, the sign of the...

The excessive complexity and burden of the Brazilian tax system, riddled by cumulative indirect taxes and heavy payroll contributions, have led to an accumulation of fiscal incentives aimed at reducing its burden on taxpayers and productive activities. Federal and subnational tax expenditures...

Auf die Energiepreiskrise, die bereits Ende des Jahres 2021 begann und durch den russischen Angriffskrieg auf die Ukraine verschärft wurde, hat die Bundesregierung mit 28 Maßnahmen in drei Entlastungspaketen reagiert, die insgesamt für den Zeitraum von 2022 bis 2024 einen Umfang von knapp 240...

Despite this phenomenal success and the Biden administration’s strong support, a divided Congress narrowly failed to extend these enhancements to 2022. The adverse impact was immediate. The January 2022 monthly child poverty rate increased by more than 40 percent to 17 percent in January 2022,...

One of the most notable examples of U.S. tax exceptionalism is the taxation of U.S. citizens and legal permanent residents (LPRs) on their worldwide income, regardless of residence. The United States also imposes broad and increasingly onerous tax and financial reporting obligations on its...

It is difficult to value fractional interests in art because there is virtually no market in those interests. Nevertheless, the Tax Court in Estate of Elkins valued the decedent's fractional interests in multiple artworks, which the decedent and his children highly cherished. First, the court...

In Sommers, ruling on both parties' motions for partial summary judgment, the Tax Court dealt with claims of issue preclusion and collateral estoppel, equitable apportionment, the completion of gifts of limited liability company interests, and retained powers that would cause estate tax...

On January 1, 2013, the federal estate tax regime in effect from 2001 to 2012 is scheduled to revert to its pre-2001 structure. A 35% rate will soar to a 55% rate. A $5 million exemption will plummet to $1 million. Some deductions and credits enacted in 2001 will disappear while others repealed...

This Article addresses the legal consequences a taxpayer should consider when deciding whether to comply with the basic requirements of the federal income tax laws. A taxpayer considering noncompliance should consider the government's authority to assert criminal liability, impose civil tax...