This paper aims to provide an overview of the current state of taxation in the Latin America and Caribbean (LAC) region, and its main reform needs and options. It previews the findings of recent studies prepared or commissioned by the Inter-American Development Bank (IDB) for its forthcoming...

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...

State governments in Nigeria are saddled with a lot of responsibilities that are geared towards the development of their areas. To do this, they engage in real asset investments that are at times overwhelming, especially when compared with their limited financial resources. This problem of...

I.R.C. § 6323, which governs how the federal tax lien ranks against the interests of the taxpayer's other creditors, subordinates the tax lien to the claims of other creditors in various ways. Tax lien subordination is commonly justified on the grounds that it enhances taxpayer asset value,...

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 Some deductions and credits enacted in 2001 will disappear while others repealed...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 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 uniquely American definition of “tax residency,” which includes the imposition of worldwide taxation on the tax residents of other countries, has delegated to the IRS the job of implementing three separate and distinct tax systems: residence, source, and extraterritorial. Through its...

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...

Virtually every tax system relies upon accurate asset valuations. In some cases, this is an easy identification exercise, and the exact fair market value of an asset is readily ascertainable. Often, however, the reverse is true, and ascertaining an asset’s fair market value yields, at best, a...