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Full-Text Articles in Law
I Got 99 Problems And They’Re All Fatca, Nirav (Jonathan) Dhanawade
I Got 99 Problems And They’Re All Fatca, Nirav (Jonathan) Dhanawade
Northwestern Journal of International Law & Business
Offshore personal income tax evasion accounts for approximately $50 billion in annual lost revenue for the United States. These large sums of money are squirrelled away in tax havens—jurisdictions, such as Aruba, the Cayman Islands, and Dubai, whose laws allow some U.S. citizens to evade paying their U.S. income taxes. Before the Foreign Account Tax Compliance Act (FATCA) was enacted, U.S. citizens could avoid taxes on passive income by not reporting this income to the Internal Revenue Service (IRS). To detect tax evasion, the IRS pursued U.S. citizens with undeclared assets in foreign banks. But the IRS’s quest was largely …
The Quest To Tax Financial Income In A Global Economy: Emerging To An Allocation Phase, Ilan Benshalom
The Quest To Tax Financial Income In A Global Economy: Emerging To An Allocation Phase, Ilan Benshalom
Faculty Working Papers
The taxation of the income derived from financial assets and transactions was always a daunting black hole in the income tax regime. In an integrated global market, tax authorities find it hard to tax financial income because of the high demand for financial investments and the mobility, fungibility, and tax-sensitivity of financial assets. Many of the current approaches to solving international tax allocation problems fail to see that financial transactions present special challenges and therefore their allocation treatment requires a special solution. The Article focuses on the most conceptually intriguing and significant problem associated with the allocation of financial income: …