Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Articles 1 - 11 of 11

Full-Text Articles in Law

How May The United States Leverage Its Fatca Iga Bilateral Process To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments? A Carrot & Stick Policy Proposal, William Byrnes Jun 2018

How May The United States Leverage Its Fatca Iga Bilateral Process To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments? A Carrot & Stick Policy Proposal, William Byrnes

William H. Byrnes

Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International’s corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages, even prolongs, the bad behavior of black hat governments by providing fuel (financial information) to feed the fire of corruption and suppression of rivals. Professor Byrnes recommends that the United States leverage a “carrot-stick” policy tool to incentivize bad actors to adopt best tax administration practices.


How May The United States Leverage Fatca To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments?, William H. Byrnes Feb 2017

How May The United States Leverage Fatca To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments?, William H. Byrnes

William H. Byrnes

This Essay serves as a preliminary narrative to examine the serious challenge of Control Firsters’ vision that every jurisdiction should have complete information on all transactions by any taxpayer. The world has many, potentially a majority, of grey hat and black hat governments and tax administrations. One measure of which governments fall into these categories is Transparency International’s corruption index. Of 167 countries ranked by Transparency International for breadth of corruption from one hundred (very clean) to zero (highly corrupt/failed state), only fifty countries ranked above a score of fifty, and only twelve scored above eighty. A question that Control …


Paradigm Shift Of The Tax Avoidance Concept: A Comparative View, William Byrnes Mar 2015

Paradigm Shift Of The Tax Avoidance Concept: A Comparative View, William Byrnes

William H. Byrnes

No abstract provided.


Equivalent Tax Self Certification Under Fatca, Gatca And The Eu Tsd, William Byrnes Nov 2014

Equivalent Tax Self Certification Under Fatca, Gatca And The Eu Tsd, William Byrnes

William H. Byrnes

No abstract provided.


Comparing The Equivalency Of The New Crs, Bba, And Us Ben Owner Reporting Forms, What’S A Financial Institution To Do?, William Byrnes Nov 2014

Comparing The Equivalency Of The New Crs, Bba, And Us Ben Owner Reporting Forms, What’S A Financial Institution To Do?, William Byrnes

William H. Byrnes

No abstract provided.


Implementing Treasury And Irs Amendments For Nffes; Determining Ffis And Payee Status; Complying With Igas, Withholding And Reporting Rules, William Byrnes Jun 2014

Implementing Treasury And Irs Amendments For Nffes; Determining Ffis And Payee Status; Complying With Igas, Withholding And Reporting Rules, William Byrnes

William H. Byrnes

No abstract provided.


Burning Issues For International Tax Career Seekers, William Byrnes Apr 2014

Burning Issues For International Tax Career Seekers, William Byrnes

William H. Byrnes

No abstract provided.


How New Custody Rule Impacts Cpa Financial Planners, William Byrnes Jan 2011

How New Custody Rule Impacts Cpa Financial Planners, William Byrnes

William H. Byrnes

No abstract provided.


Tax Risk Management: The Relationship Circle, William Byrnes Oct 2008

Tax Risk Management: The Relationship Circle, William Byrnes

William H. Byrnes

No abstract provided.


Transfer Pricing: Multi-Purpose Functional Analysis (Tax Department As The Hero), William Byrnes Oct 2008

Transfer Pricing: Multi-Purpose Functional Analysis (Tax Department As The Hero), William Byrnes

William H. Byrnes

No abstract provided.


Obtaining The Skills Required For Performing Tax Process Outsourcing, William Byrnes May 2007

Obtaining The Skills Required For Performing Tax Process Outsourcing, William Byrnes

William H. Byrnes

No abstract provided.