Adam S. Wallwork is an Attorney in the New York City office of Osler, Hoskin & Harcourt LLC, where his practice focuses on federal income taxation. Mr. Wallwork provides a novel look at the Tax Court's doctrine of preparer fraud, which recently provoked a circuit split. He shows that that...

Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore...

This paper examines ethical and behavioral aspects of taxpayers, the financial condition of citizens, tax fairness, taxpayer services, complexities in the tax regime, tax rates, penalties and enforcement, and tax amnesties and the black economy. Primary data were collected by conducting a survey...

The “qualified business income” deduction was added as section 199A to the Internal Revenue Code of 1986 (as amended) in December 2017 by the Tax Cuts and Jobs Act [Pub. L. No. 115-97, 131 Stat. 2054, 11011 (2017)]. Subject to a number of limitations, the section 199A deduction is generally...

This chapter is divided into three main parts: 1) international tax law, 2) domestic tax law, and 3) tax and regulation. The first part deals with the international tax system and the way it has been affected by technology. This part will focus on income tax. Existing rules of nexus,...

E-filing of income tax return can be seen as an important means to enhance the value of services to the citizen. This paper investigates whether tax knowledge influences the level of intention of individual taxpayers to use E-filing after five years of its implementation in Bangladesh. The study...

Taking Singapore as an example, this article lays out a series of tests for determining whether gains arising from the disposal of cryptocurrencies are trade or business income, “all other income” or capital gains. It also considers the possibility of a presumption that individuals engaging...

When digital tokens are used in debt finance, one cannot assume that the same orthodox tax treatment will apply. The highly specific nature of tax provisions means that they may apply very differently once digital tokens rather than fiat currency are involved. Through a case study of Singapore...

The post highlights three main issues that may result from the rapid and widespread automation of jobs: 1) declining tax revenues; 2) inequitable distribution of gains and losses from automation; and 3) social costs of job displacement, such as social support and retraining programmes for...

The key points we made in the article are as follows:1) One might think that because income from transactions involving cryptocurrencies is taxable, the losses from such transactions would also be deductible. Unfortunately, the situation is not quite so straightforward.2) The key question is...