Has a $5.00 shipping fee ever made you second guess an online purchase? What about a sales tax? Apparently, our Supreme Court Justices pay no mind to the latter. South Dakota v. Wayfair annihilates the concept of tax-free online shopping and allows the states to compel online companies meeting...

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,...

Adam S. Wallwork is an Attorney in the New York City office of Osler, Hoskin & Harcourt LLC, where his practice focuses on federal income taxation. Mr. Wallwork provides a novel look at the Tax Court's doctrine of preparer fraud, which recently provoked a circuit split. He shows that that...

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 “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...

E-filing of income tax return can be seen as an important means to enhance the value of services to the citizen. This paper investigates whether tax knowledge influences the level of intention of individual taxpayers to use E-filing after five years of its implementation in Bangladesh. The study...

Getting tax and transfer systems to efficiently deliver sufficient revenues to achieve macroeconomic targets, address goals in re-distribution and social welfare, encourage employment, accommodate business-competitiveness concerns and incorporate environmental issues is difficult. In Australia,...

For individual taxpayers engaged in offshore tax evasion, the U.S. government has issued a clarion call of deterrence best summarized in the song made famous by Martha and the Vandellas: “Nowhere to run to; nowhere to hide.” Yet, the jury is still out — literally — for most bankers,...

Since the turn of the current century, leading transnational organizations and academic scholarship have identified tax competition among countries as one of the scourges of the international tax regime. Both the EU and the OECD have warned that tax competition erodes the tax bases of Member...

Hong Kong is not a tax haven, but is probably the only international financial centre that is not covered by a Double Tax Agreement (DTA). The relevant DTAs between the People's Republic of China (PRC) and the UK, the PRC and Australia or the PRC and the US do not apply to Hong Kong. This is...