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...