The draft for a CCCTB Directive in the EU includes the suggestion for an apportionment formula which allocates taxable profits to group member corporations and to the respective Member States. The draft directive delegates the right to define one apportionment factor, the term ‘Employee’ to...

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...

Executives use a variety of manipulative games to maximize the value of their gifts, including backdating, spring-loading, bullet-dodging and insider information. We find that executives exploit a legal loophole to backdate their gifts. Stock prices rise abnormally about 6% during the one-year...

The VAT is compared to a turnover tax (TT) given monopoly final goods and intermediate goods firms interacting strategically. Linear demands and constant costs are assumed. Via examples it is shown that for both "Cournot" and "Stackelberg" games, a revenue neutral VAT may not exist to a given...

NOTE: The following is a description of the paper and not the actual abstract. Equilibrium tax and expenditure policies are studied in a federation consisting of a federal government and several state governments. Each state begins with an initial distribution of residents of different ability...

We use data multinational firms provide to the Internal Revenue Service regarding their foreign subsidiary locations to explore whether some firms fail to publicly disclose subsidiaries in some countries, even when the subsidiaries are significant and should be disclosed per Security and...