This National Report was prepared for the 2014 Annual Congress of the European Association of Tax Law Professors, which took place in May 2014 at Koç University, Istanbul, Turkey. This National Report discusses administrative and legal mechanisms, especially the Foreign Account Tax Compliance...

This National Report was prepared for a conference titled Tax Secrecy and Tax Transparency – The Relevance of Confidentiality in Tax Law, which took place in July 2012 in Rust, Austria and was co-hosted by the Institute for Austrian and International Tax Law at the Vienna University of...

The terms “enterprise,” “business” and “business profits” are ubiquitous in U.S. and international tax law yet they are often ill-defined and under-theorized, especially in their interaction with other regulatory areas. This U.S. Report, commissioned for a comparative volume on the...

The Internal Revenue Code is riddled with features that allow U.S. taxpayers to reduce their federal tax liability by operating through tax haven companies. Some of these provisions are historic anomalies. Others are better understood as inadvertent loopholes than considered legislative grace....

The Protecting Americans from Tax Hikes (PATH) Act of 2015 was recently signed into law by the US President Obama, and one provision (section 126) in particular benefits venture capital, private equity, and other investors owning or planning to purchase a US corporation

This paper analyzes the sources of heterogeneity in legal tax avoidance strategies across individuals. Three conditions are required for a taxpayer to participate in tax avoidance: incentive, access, and awareness. Using rich Swedish administrative panel data with a unique link between corporate...

This article discusses the task of identifying controlled transactions under review by the Commissioner of the Internal Revenue Service. In particular, it aims to alert courts as to the necessary role of contractual interpretation law in determining the true nature of such controlled transactions

In this paper, we discuss the hypothetical impact of the Amount A regime on US corporate income tax revenue. The general outline of the two-pillar taxation system, which includes Amount A as a part of Pillar One, was agreed upon in October 2021 by the Inclusive Framework delegates who tackled...

This is the General Report for the United States on the theme of “Surcharges and Penalties in Tax Law” for the 2015 meeting of the European Association of Tax Law Professors in Milan, Italy. The Report addresses questions relating to the treatment of civil penalties, criminal penalties and...