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Full-Text Articles in Law
Are Cryptocurrencies 'Super' Tax Havens?, Omri Y. Marian
Are Cryptocurrencies 'Super' Tax Havens?, Omri Y. Marian
Omri Y Marian
I describe the mechanisms by which cryptocurrencies — a subcategory of virtual currencies — could replace tax havens as the weapon-of-choice for tax-evaders. I argue such outcome is reasonably expected in the foreseeable future due to the contemporary convergence of two processes. The first process is the increasing popularity of cryptocurrencies, of which Bitcoin is the most widely recognized example. The second process is the transformation of financial intermediaries to agents in the service of tax authorities, as part of the fight against offshore tax evasion. Financial institutions are faced with increased governmental pressure to deliver information about account holders, …
Meaningless Comparisons: Corporate Tax Reform Discourse In The United States, Omri Y. Marian
Meaningless Comparisons: Corporate Tax Reform Discourse In The United States, Omri Y. Marian
Omri Y Marian
This article examines the role that international comparisons play in current corporate tax reform discourse in the United States. Citing the need to make the U.S. corporate tax system more competitive, comparisons are frequently used to assess other jurisdictions' tax-competitiveness, and many legislative proposals are supported by such comparative arguments. Examining such discourse against the background of several theoretical approaches to comparative law, this article argues that, to the extent that comparisons are aimed at providing guidance for prospective reform, this purpose is not well served. Participants in the corporate tax reform discourse, from both sides of the aisle, lack …