Some countries are undertaking, and others considering, self-examination rules to detect whether proposed tax reforms might have a negative impact on tax policy or economic outcomes in less affluent countries. The impetus for this kind of analysis is a loosely articulated idea that states may...

National tax policy is one product of the classic Lockean social contract between individuals and government. But countries are now so economically interdependent that one nation's tax policies can profoundly undermine another's attempts to implement the bargain. This article argues that tax...

The extent of the information subjected to automatic exchange under the scope of cross border tax administrative cooperation is increasing day by day. Nowadays, financial accounts, non-financial categories (such as changes of domicile, immovable property acquisitions and transfers, value added...

The IRS recently announced that its mandatory registration regime for paid tax return preparers, struck down in the Loving decision, would henceforth be offered as a voluntary program. But the authors of this program appear to have forgotten that the US system is perfectly global in reach,...

French Abstract: Le thème central du livre est celui de la compétition fiscale qui oppose les États à l'échelle internationale. Abordant cet enjeu, Dietsch présente une solution interdisciplinaire au problème qui touche tant l'économie que le droit et la philosophie. Notre recension...

The United States enacted a tax reform in 2010 known as the Foreign Account Tax Compliance Act (FATCA), which will impose an extensive third-party monitoring and disclosure regime on financial institutions around the world in an effort to “smoke out” American tax cheats and expose their...

When Congress enacted the Foreign Account Tax Compliance Act in 2010, it made no mention of any internationally-agreed alternative to its enforcement, and Congress has made no authorization since then for the president to override FATCA's statutory provisions by international agreement. Yet due...

Transnational tax information cooperation has the crucial role of empowering tax administrations to collect tax revenues in full and on time, thereby narrowing the tax gap created by international evasion and avoidance. However, the adequacy of established transnational tax information exchange...

Tax reform is a constant process in most nations as governments continuously revisit their tax regimes in response to economic, social, and political forces. Domestic legislative processes are the most obvious source of change in the tax system in any independent nation, but international...

In its first term, the Obama administration enacted two pieces of legislation, each designed to protect an increasingly vulnerable income tax base, and each of which had the potential to set a new and unprecedented course for no less than the regulation of the global economy by the nation-state....