This chapter suggests a rationale for a simple, scalable, and fast computational approach through the ‘Data With Direction Specification’ (DWDS) to supplement the implementation of the African Continental Free Trade Area (AfCFTA). The specification provides a way for digitally executable...

Abuse is one of the core issues in EU direct tax matters. Much has been written over the past years. The discussion on the interpretation and application of the different elements of the anti-abuse clauses appears to be settling. However, an equally fascinating discussion appears to be emerging:...

The OECD recently emerged as the site of unprecedented, multilateral, and seemingly high-stakes negotiations about the future of international business income taxation. Judging by the political resources deployed in these negotiations, international tax has entered unchartered territory....

Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...

Against a backdrop of ongoing angst regarding release of tax guidance, an important idea has surfaced in the tax compliance literature. Prominent tax compliance scholars have argued that the strategic use of tax law uncertainty may cause taxpayers to report higher tax liability. While these...

In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

The latest wave in tax shelter reform is the recent codification of the so-called “economic substance doctrine” and the accompanying strict liability penalty for violations of the doctrine. The new strict liability penalty has been criticized by tax scholars and practitioners for being...

Peracchi v. Commissioner is a lightning rod for commentators and the bane of students of corporate income tax. In short, the decision makes no sense because it grants the maker of a note a section 1012 basis in the note, violating a fundamental principle of income taxation. Nonetheless, the...

Service tax is imposed on renting of immovable property for use in business or commerce. Residential properties are not subject to tax. This article examines use of residential property partly for business or commerce and service tax implications thereon

Because the tax law makes many distinctions not based on fundamental economic differences, taxpayers can exploit these inconsistencies to create opportunities for tax arbitrage. This article argues that any interpretative system which requires consistency in the application of rules where the...