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...

We develop a model of capital income tax competition where taxation can discriminate between different kinds of capital income (corporate income, interest income, and dividends) and various rules of international taxation can be applied. The firms' capital structures and the nature of the...

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...

Taxation under oligopoly is analysed in a general equilibrium setting where the firms are large relative to the size of the economy and maximise the utility of their shareholders. It turns out that the model is an aggregative game, which simplifies the comparative statics for the effects of...

We propose a game-theoretic investigation to capture the interplay between the behavior of tax consultants, taxpayers, and the tax authority in a setting of tax complexity. Our purpose is to provide answers to two research questions: Which aspects of the strategic interaction between the players...

The issue of capital tax competition in source-based capital taxes is viewed to be unproblematic if residence-based capital taxation exists. The sustainability, however, of residence-based capital taxation depends on the co-operation of source countries to assist in collecting tax revenues that...

The issue of capital tax competition in source-based capital taxes is viewed to be unproblematic if residence-based capital taxation exists. The sustainability, however, of residence-based capital taxation depends on the co-operation of source countries to assist in collecting tax revenues that...

According to conventional wisdom internationally mobile capital should not be taxed or should be taxed at a lower rate than labour. An important underlying assumption behind this view is that there are no market imperfections, in particular that labour markets clear competitively. At least for...