This paper seeks to expose the origins and impacts of electronic commerce on tax revenues, especially with regard to services and intangibles good transferable via download, making an analysis of the international scenario. Therefore, portrays the rise of the internet and its popularization,...

Canadian National Report prepared for the Vienna University of Economics and Business, Conference on tax secrecy and transparency, Rust, Austria, July, 2012. The aim of the project is to assess how different countries regard the treatment of tax information and tax secrecy. Topics include the...

In the Netherlands, special tax incentives apply for so called ‘public benefit pursuing entities' (hereinafter PBEs). Currently, the Dutch tax authorities have registered 50.000 PBEs. The main criterion is not whether the activities or the entities are not for profit, but whether these...

Accounting for the interests of the environment in tax law means teaching a balance between the tax system and environmental protection, between ability to pay considerations and the polluter pays principle. To create a large number of environmental taxes would make the tax system incoherent and...

Although the field of comparative tax law has achieved greater prominence in legal studies, its methodology is not yet adequately developed. In general, work in comparative tax has not focused adequately on specific features of tax law. This paper proposes a comparative methodology specifically...

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...

Governments attack tax avoidance in a number of ways. Statutory anti-avoidance rules are one means. Such rules come in two forms: specific and general. General rules potentially apply to any kind of transaction that may result in tax avoidance. Section 99 of the New Zealand income Tax Act 1976...

Section 67 of the Income Tax Act 1976 taxes as income certain gains on the sale of land that would ordinarily be classed as capital. Several proposals were made to repeal the section or severely to limit its effect. The article argues that the section contains a number of flaws, though none that...

Among the possible responses to the problem of avoidance a country may enact a general anti-avoidance rule, couched in terms wide enough to frustrate tax planning strategies that have yet to be invented. One difficulty of general anti-avoidance rules is that they cannot be interpreted as undoing...

The United States tax classification of a “foundation” created under the laws of a foreign jurisdiction is a complicated matter. “Foundations” are not creatures of common law, but are derived from civil law. The United States follows common law and this body of jurisprudence is more...