Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Taxation-Federal
The Irs’S Voluntary Disclosure Program: Need For Codification, Jay A. Soled
The Irs’S Voluntary Disclosure Program: Need For Codification, Jay A. Soled
Georgia State University Law Review
For more than a century, the Internal Revenue Service (IRS) has had a voluntary disclosure program in place. Its purpose is to coax into tax compliance those wayward taxpayers who have committed criminal acts or have been remiss in fulfilling their civic tax-filing obligations. Historically, the voluntary disclosure program has had to strike a difficult balance between being attractive enough to entice tax scofflaws to participate and not being too attractive lest ordinary taxpayers feel that their compliance efforts were for naught.
A unique feature of the voluntary disclosure program is that it is entirely administrative in origin. The commissioner …
The Surprising Significance Of De Minimis Tax Rules, Leigh Osofsky, Kathleen Delaney Thomas
The Surprising Significance Of De Minimis Tax Rules, Leigh Osofsky, Kathleen Delaney Thomas
Washington and Lee Law Review
De minimis tax rules—rules that eliminate tax burdens for low-income taxpayers or low-dollar transactions—abound in the tax law. Despite the prevalence of such rules, legal scholarship has treated them as—well—de minimis, or as mere rounding errors that do not merit sustained attention. This perspective is understandable. If de minimis rules address insignificant taxpayers or tax liabilities, aren’t the rules themselves likely to be insignificant?
Recent tax law developments have revealed that this conception of de minimis tax rules is deeply misguided. Major allocations of tax law liability, as well as accompanying questions about the fairness, efficiency, and administrability of the …