The worldwide rise of the Value-Added Tax (VAT) over the last half-century is emblematic of the paradox in modern tax systems: their remarkable similarity in the face of divergent political, cultural and social systems. However efforts to introduce VAT-style taxes have frequently been...

Vodafone acquired Hutchison (India) in 2007. Post-acquisition Vodafone has faced a turbulent time dealing with the tax authorities. The liability on Vodafone to withhold Capital Gains Tax was upheld by the Bombay High Court but subsequently rejected by the Indian Apex Court. However, the matter...

The Internet has completely changed the landscape of the planet. As a result, many areas of the law are being re-thought or re-developed, while other new issues emerge that defy all remotely related regulations. Online gambling is one of those areas in which the laws have lagged behind the...

Funding higher education is among the critical financial decisions made by individuals and families. There are myriad options. Yet, the conventional wisdom — namely using Section 529 Plans — may not be the optimal vehicle to effectuate this goal. Therefore, this Article discusses various...

This Article explores the circumstances in which tax deferral is beneficial, and derives some basic rules that refine the prevailing view that deferring taxes saves money. It demonstrates that Roth IRAs are often more attractive than traditional tax-deferred retirement plans but for a reason...

Confidence Games provides an account of the wave of tax shelters that occurred at the turn of the twenty-first century. During this period, some of America's most prominent law and accounting firms created and marketed products that enabled the very rich — including newly minted dot-com...

This past July 1 marked a Tax Shelter anniversary. On that date twelve years ago, the IRS issued Notice 2003-47, challenging the deferral of income by corporate executives using the so-called ECS, an acronym variously interpreted to mean the Executive Compensation Solution, the Executive...

The process used to select the hosts of the Olympic Games is under increased scrutiny due to the withdrawal of many cities from the 2022 Winter Olympic Games host selection process, and the selection of hosts with questionable human rights records. Scholarship, particularly legal scholarship,...

When examining a corporate taxpayer, the IRS often seeks special accounting documents called tax accrual workpapers. These workpapers often contain privileged documents, but the IRS does not care. It believes it is entitled to the documents despite that the work product doctrine protects the...