In der rechtspolitischen Diskussion um eine Regulierung von Managementvergütungen wird von mehreren Parteien gefordert, den Betriebsausgabenabzug für Vorstandsgehälter einzuschränken, um die als überhöht angesehenen Vergütungen zu begrenzen und die "Subvention" durch die Steuerzahler zu...

This is the tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates multiple provisions of international human rights instruments that have been signed, or signed and ratified, by the United States. The rights in question...

The philanthropic sector is highly consequential, particularly in the United States, and the most important policies directed toward this sector are tax policies. Yet most economic analysis of the optimal tax treatment of charitable giving is ad hoc, treating it as a subject unto itself. This...

This article explains how some provisions related to section 529 college savings plans in the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019 conflict with existing tax law provisions, and provides policy change recommendations to help eliminate that conflict. If...

When consumers have questions about companies' services and products, whether medical insurance, airline tickets or home appliances, they almost always encounter automated agents and other forms of customer service technology. Increasingly, tax authorities have begun to offer online...

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...

This Article addresses the legal consequences a taxpayer should consider when deciding whether to comply with the basic requirements of the federal income tax laws. A taxpayer considering noncompliance should consider the government's authority to assert criminal liability, impose civil tax...

This paper argues that there is too great a reliance placed on anti-avoidance provisions, discretions reposed in the revenue, and judicially developed doctrines as a means of countering tax avoidance. In view of the difficulties in defining and countering tax avoidance, it is suggested that...

With acknowledgment of the growing popularity of the trust as an effective taxation planning vehicle, this article explores various principles of taxing trusts under the Land and Income Tax Act 1956. The author first analyses the requirements of sections 155(a) and 155(b) of the Act and the...