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Free competition: how tax evasion and tax competition distort markets – the Brazilian perspective

Igor Mauler Santiago
ABSTRACT The article discusses how tax evasion and tax competition jeopardise free competition between companies. Focusing on the Brazilian experience, it shows that the country is not a major player in international tax competition, but that there is a ferocious tax war between Brazilian States and Municipalities. The article describes the two main examples of this internal tax competition and presents some of the...
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Case Study Research and International Tax Theory

Allison Christians
Abstract Over the last ten years, legal scholars have begun to use what they describe as “case studies” in an effort to develop better theories about how governments can or should impose taxation on international activities. The attributes and function of case studies, while well-studied and documented in other disciplines, has not been explored in tax law scholarship. This Article explores case study research...
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A Technical Analysis of Proposed Section 710

Howard Abrams
I. Introduction Representative Charles B. Rangel (D-NY), Chairman of the House Committee on Ways and Means, introduced on October 25, 2007, a comprehensive tax reform bill (H.R. 3970) which includes proposed new section 710 of the Internal Revenue Code. This provision also has been included in the Temporary Tax Relief Act of 2007 (H.R. 3996), introduced by Chairman Rangel on October 30, 2007. Proposed section 710...
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The Unhappy Marriage of Law and Equity in Joint Return Liability

Bryan T. Camp
It is no accident that Justice Holmes penned those words in a tax case. Of all the corners in all the laws governing citizen interaction with government, tax laws contain some of the squarest. Today’s column discusses what happens when Congress attempts to smooth out the sharp corners of the tax code with notions of equity, but does so with an inadequate understanding of, or appreciation for, the problems of tax administration....
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Tax Competition, Foreign Direct Investments and Growth: Using the Tax System to Promote Developing Countries

Yoram Margalioth
I. INTRODUCTION AND BACKGROUND INFORMATION The world population is approximately six billion people. 1.2 billion, or one-fifth, are rich while 4.8 billion, or four-fifths, are poor.[1]  The world is more unequal today than at any time in world history. (2)  Only 240 years ago, at the beginning of the industrial revolution, most everybody was poor. Author Lant Pritchett explains that very poor nations today are just...
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Slinking Away From Twinkie Taxes

Joel Newman
‘‘A tax can be a means for raising revenue, or a device for regulating conduct, or both.’’ — Felix Frankfurter[1] ‘‘Frankly, I think government shouldn’t have a darn thing to do with what we sell or how our customers eat. As long as it is safe, tastes good and is fair priced, why should the mayor care?’’ — Frances Sack, operating partner, Dalessandro’s, a chain of cheesesteak restaurants in...
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Fiscal Policy and Capital Formation in Transition Economies

Grzegorz Kolodko
SUMMARY In the 199Os the transition economies of Eastern Europe and the former Soviet Union have suffered significant recession and persistent imbalances. Over ten years of vast changes GDP has contracted significantly and income inequality increased, too. In several countries post-socialist depression still continues. Whereas in the best example, that is Poland, GDP in 1999 is at about 12O percent of pre-transition...
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Amended Returns – Imposing a Duty to Correct Material Mistakes

Calvin Johnson
T. Keith Fogg The amended return proposal would require a taxpayer to file an amended return to correct an innocent factual error large enough to be worth correcting once the error is discovered. Failure to correct a prior representation on discovery of its falseness is a form of deceit under American nontax law. A taxpayer should not deceive his government.[1] I. Current Law A. Internal Revenue Code The Internal...
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Comments on the OECD Proposal for Secret and Mandatory Arbitration of International Tax Disputes

Michael Mcintyre
The OECD has proposed amendments to its Model Tax Convention and Commentary that would establish a system for the mandatory arbitration of tax disputes between two treaty countries when the tax officials of those countries have been unable to resolve those disputes within a two-year period.[1] The proposal is undoubtedly well-meaning and does address a small but significant problem - the "rare cases" (OECD characterization)[2]...
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The Play’s the Thing: A Theory of Taxing Virtual Worlds

Bryan T. Camp
Introduction Taxation is shadow life. As our culture monetizes more and more life activities, the shadow grows. This Article looks at the potential tax issues arising from a new life activity: online role-playing games in virtual worlds. Currently, some thirty million people regularly play such games and the number is growing.[1] Exploring the reach of the Tax Code into virtual world transactions not only responds...
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