This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be...

Future increases to the top income tax rates for individuals and reductions to the corporate tax rate will invite the widespread use of C corporations as tax shelter vehicles, an old problem that has never been addressed successfully. The changes could even resurrect the need for the...

A core problem for enforcement of tax laws is asymmetric information. The taxpayer knows the facts regarding the relevant transactions it engages in during the year-or at least has ready access to that information. The government is forced to play catch-up, obtaining that information either from...

In 1944, Martin Crowe, a Catholic priest, wrote a doctoral dissertation titled The Moral Obligation of Paying Just Taxes. His dissertation summarized and analyzed 500 years of theological and philosophical debate on this topic, which identified three basic philosophical positions on the issue....

This Symposium Essay compares current patterns and practices surrounding IRS utilization of IRB guidance (revenue rulings, revenue procedures, and notices) with administrative law doctrine concerning informal agency guidance documents. In administrative law jurisprudence, the distinction between...

The probabilities associated with a tax return being audited or containing underreported tax are formulated here in a different way. This new formulation is mathematically equivalent to the traditional formulation; however, it reveals a trigonometric relationship between these probabilities that...

Tax reform and religion were two of the hot button issues during the last election. While at first glance these issues seem unrelated, a number of scholars have argued that religious values should guide our decisions regarding tax reform. This article posits that the relationship between...

When taxpayers underreport their income, understate their income, or fail to file their tax returns the government must spend money to audit taxpayers, to assess the tax, to collect the tax, and to borrow money to cover the lost revenue. The amount of such noncompliance with the tax laws is...

Evident on both sides of the Tasman has been an increase in the use of trusts for tax planning purposes, brought about by high tax rates in the middle income ranges. This article seeks to answer why the trust is such a successful vehicle for income tax planning, discussing the scheme and...