The ability of the Internal Revenue Service (IRS) to both collect the tax and enforce the initial determination of tax liability in a neutral and fair manner has been compromised by a February 2011 pronouncement issued by the Department of Justice (“Justice”) stating that the President and...

Governments are increasingly turning to behavioral economics to inform policy design in areas like health care, the environment, and financial decision-making. Research shows that small behavioral interventions, referred to as “nudges,” often produce significant responses at a low cost. The...

Considering the need to broaden the tax base and to increase tax revenue in an efficient, equitable, and cost-effective manner, this paper analyzes presumptive taxation methods and their application in sub-Saharan Africa. Presumptive taxation involves simple techniques to capture income that...

This paper develops and solves a model of a multinational firm, who has the option to shift its earnings to a low-tax haven nation. Given the behaviour of the multinational firm, the haven nation solves a Ramsey optimal taxation problem, which involves choosing corporate and personal tax rates....

Technological advancements are playing a transformative role in curtailing the need for labor. These very same forces are catapulting capital in the form of robotics, machinery, and intellectual property to the economic forefront. In virtually every sphere of human existence, labor's decline and...

The international taxation of multinational enterprises (MNEs) stands under public and political pressure. The OECD BEPS project is striving for taxation in line with economic activity and value creation. While this might prevent book profit shifting it comes at the risk of investment shifting...

This Article begins by tracing the evolution of the accumulated earnings tax and the personal holding company tax from their origins to the mid-1980s. The Article then demonstrates the limited extent to which these corporate penalty taxes serve their historical purpose of preventing taxpayers...

This note reviews May 2019 OECD framework agreement report, “OECD/G20 Inclusive Framework on BEPS: Progress Report July 2018-May 2019” on international taxation of the ‘digital economy'. The core conclusions of the review are:1. The framework agreement proposals to-date represent complex,...

When a debtor goes bankrupt and limited assets have to be divided between competing creditors, should unpaid taxes owed to the government be paid before the debts owed to other creditors? This Article defends the notion that some tax debts should be awarded priority. Insofar as bankruptcy...