This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

This article evaluates recent state cases upholding a retroactive amendment of a tax statute that reversed a judicial interpretation of the predecessor statute. Practitioners have criticized these cases because the seeming length of the statute's retroactivity has typically been lengthy. The...

There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S....

In recent years, Canada's courts have expressed a number of conflicting views about whether the parol evidence rule can be invoked by or against the Minister of National Revenue (Minister) in tax disputes. Unfortunately, the courts in these cases did not elaborate, to a sufficient extent, on the...

Using data on U.S. state and federal taxes and transfers over a quarter century, we estimate a regression model that yields the marginal effect of any shift of market income share from one quintile to another on the entire post tax, post-transfer income distribution. We identify exogenous income...

In Part IV, Dean Marsan examines FATCA withholding liability for withholdable payments under Code Secs. 1471 and 1472, and provides a nine-point analysis - each of which must be answered affirmatively for the new 30-percent withholding tax to apply

One of the most notable examples of U.S. tax exceptionalism is the taxation of U.S. citizens and legal permanent residents (LPRs) on their worldwide income, regardless of residence. The United States also imposes broad and increasingly onerous tax and financial reporting obligations on its...

This Article compares the ways in which the United States and the European Union limit the ability of state-level entities to subsidize their own residents, whether through direct subsidies or through tax expenditures. It uses four recent charitable giving cases decided by the European Court of...

This article continues what has now become a comprehensive series examining the new U.S. reporting and withholding system for foreign account tax compliance. Part VI provides a new four-point analysis to determine if an FFI or USFI has a withholding tax liability for pass-through payments under...

This study examines when and how tax reform impacts the pricing of IPOs. Using the Tax Cuts and Jobs Act of 2017 (TCJA), we examine IPO pricing during the periods of anticipated and post-tax reform. First, we document that firms completing an IPO following the passage of the TCJA experience an...