Die Abhandlung ist eine überarbeitete und erweiterte Fassung der vom Institute for Monetary and Financial Stability am 19. Juni 2006 veranstalteten Guest Lecture des Autors zum Thema "Demystifying Hedge Funds"

This article briefly traces the history of tax sheltering in the latter half of the twentieth century in the United States, including the transformation of the role of tax professionals from support functions in tax planning for transactional efficiency to profit center functions through...

Demonstrates that there is no tax savings to be achieved by using a trust to restrict a donee's control of property and money transferred gifts during life or at death. Reviews reasons why donors wish to continue to control wealth even after death and suggests that such reasoning is fallacious....

The United States derives from a global income tax model under which it taxes it citizens and permanent residents on all their worldwide income without regard to the source of that income. Under a pure global model, the United States would combine income and deductions in a single tax...

Taxpayers shift income offshore with lawful devices like operating through a foreign corporation. Taxpayers have enhanced the amount of that income lodged outside the U.S. with transfer pricing strategies. And taxpayers have evaded U.S. taxation of their worldwide income by secreting assets and...

This paper questions whether late twentieth century immigration patterns may have contributed to retreat from progressive taxation in Sweden (and elsewhere). The paper applies critical methodology to ask whether the societal generosity reflected in development of Sweden’s welfare state yielded...

This chapter reviews statutory and court sanctioned private regulatory frameworks affecting the creation of private equity (PE) funds and their primary activity of acquiring corporate enterprises. The chapter reviews U.S. legislation regulating securities, investment companies, and tender...

International corporate tax competition continues to exert pressure on legislatures to reduce corporate tax rates as well as the rate imposed on shareholders. To combat this pressure, this commentary recommends eliminating the corporate income tax. Instead corporations should become tax...