Predicting the taxation of prediction markets.
TABLE OF CONTENTS
I. INTRODUCTION 954
II. BACKGROUND OF PREDICTION MARKETS 956
III. CURRENT TAXATION OF PREDICTION MARKETS . . .
Options as disguised financings: the demise of an urban tax
legend.
TABLE OF CONTENTS
I INTRODUCTION 908
II. THE FINANCING RATIONALE 911
III. DOUBTS ABOUT THE FINANCING RATIONALE . . .
Building a better GAAR.(general anti-avoidance rule)
TABLE OF CONTENTS
I. INTRODUCTION 835
II. CONEQUENTIAL ATTRIBUTES OF TAX-AVOIDANCE BEHAVIOR AND A 842
TAXONOMY REFLECTING THE . . .
Risk, return, and objective economic substance.
TABLE OF CONTENTS
I. INTRODUCTION 784
II. OBJECTIVE ECONOMIC SUBSTANCE 786
III. PRE-TAX PROFIT . . .
Turning slogans into tax policy.
TABLE OF CONTENTS
I. INTRODUCTION 747
II. ESTATE TAX REPEAL 749
A. The Economic Case Against the Estate Tax 750
B. . . .
Tax information reporting and compliance in the cross-border
context.
I. INTRODUCTION
As in the domestic context, tax information reporting in the
cross-border context serves the four-fold purpose of providing a
cross-check for the Internal Revenue Service . . .
Homage to information returns.
I. INTRODUCTION
One of the most important administrative features of the
nation's tax system involves the issuance of information returns
(such as Form W-2s and Form 1099s). Most studies indicate . . .
The netting of costs against income receipts (including damage
recoveries) produced by such costs, without barring Congress from
I. INTRODUCTION
This article principally argues that, under the federal income tax,
costs of obtaining specific sums of money should be capitalized (as
opposed to being treated as expenses), just . . .
Optimal tax compliance and penalties when the law is
uncertain.
This article examines the optimal level of tax compliance and the
optimal penalty for noncompliance in circumstances in which the
substance of the tax law is uncertain--that is, when the . . .
International tax neutrality: reconsiderations.
Tax policy in general and international income tax policy in
particular has long been a subject of discussion and argument by tax
philosophers, economists, and lawyers. Theories have often . . .
Naked and covered in Monte Carlo: a reappraisal of option
taxation.
The market for equity options and related derivatives is
staggering, covering trillions of dollars worth of assets. As a result,
the taxation of these instruments is inherently important. Moreover, . . .
Theory meets reality: the case of the double tax on material
capital.
In recent years there has been increased interest in the adoption
of a consumption tax as a replacement for the income tax. Typically it
is suggested that this result be achieved by (1) taxing only . . .
Rationalizing the taxation of reorganizations and other corporate
acquisitions.
This article examines the taxation of human shareholders in the
case of mergers and acquisitions. Currently, the relevant law is
extraordinarily complex, utterly inconsistent, and in many . . .
Taxation in developing countries: some recent support and
challenges to the conventional view.
The general advice given by international institutions such as the
International Monetary Fund (IMF) and the World Bank to developing
countries over the past few decades has been to replace trade . . .
Tax lawyers are people too.
I. INTRODUCTION
Victor Fleischer understands that to increase compliance with tax
law, we cannot simply look to a mix of legal penalties and enforcement.
He understands, too, that the role of . . .
Options backdating, tax shelters, and corporate culture.
This Essay examines the problem of tax noncompliance through the
prism of the options backdating scandal. The noncompliance of backdating
was obvious, at least to tax lawyers. Backdating wasn't . . .
Questioning the wisdom of patent protection for tax
planning.
I. INTRODUCTION
The topic of federal patent protection for tax planning strategies
has received considerable attention of late, (1) much of it from a tax
bar whose overall incredulity concerning . . .
Patents, tax shelters, and the firm.
I. INTRODUCTION
The United States patent statute offers exclusive rights in any new
and useful "process, machine, manufacture, composition of
matter" or new and useful improvements on existing . . .
Disrupting the market for tax planning.(response to article by
Philip Curry, Claire Hill, and Francesco Parisi in this issue, p.
I. INTRODUCTION
It is a pleasure to comment on Philip Curry, Claire Hill, and
Francesco Parisi's article (1) on creating market failures for tax
planning. It is rare that I get to comment on an . . .
Creating failures in the market for tax planning.
I. INTRODUCTION
Although most people recognize the necessity of taxes, few people
like to pay them. Governments expend costs to collect taxes; people
expend resources to avoid paying them, . . .
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