Skepticism about the potential of moral appeals relating to tax compliance — for example, as applied to large groups of individual taxpayers outside a wartime context — has resulted in the absence of a theory about how government communication can further tax compliance. This Article fills...

Report of Foreign Bank and Financial Accounts (“FBAR”) requirements seek to solve a pressing information asymmetry problem relating to U.S. persons' investment in non-U.S. financial accounts. FBAR reporting requires U.S. taxpayers themselves to disclose offshore account information to the...

Bilateral intergovernmental agreements (IGAs) relating to the Foreign Account Tax Compliance Act (FATCA) and entered into by the U.S. government reduce the reach of FATCA's withholding tax regime, including the reach of that regime as applied to non-U.S. taxpayers. The validity of these IGAs has...

The U.S. government has broad discretion to change the transfer pricing regulations as they apply to corporate multinationals. These regulations need changing because they give too much leeway to taxpayers and will continue to serve an important function in the division of international tax...

The emerging U.S. Foreign Account Tax Compliance Act or “FATCA” system provides an innovative model for the future of offshore information reporting. But its bank-to-residence government, or B2G, model lacks a good enforcement mechanism, because the U.S. lacks jurisdiction over the non-U.S....

U.S. income tax rules may encourage a U.S.-headquartered multinational corporation (“MNC”) to adopt a tax-haven-parented structure. We study data from firms that conducted initial public offerings in the United States between 1997 and 2010 and offer evidence that U.S.-headquartered MNCs...

Do automated or artificial intelligence systems follow the law? What design choices can the law make to encourage legal compliance by robots? Tax law has some experience with these questions. Algorithmic tax compliance robots, such as TurboTax or H&R Block Online, appear to break taxpayer data...