Tax risk management: evidence from the US

Author's pre-print draft. Final version published in British Tax Review. Available online at http://www.westlaw.co.uk/Tax risk management is a worldwide phenomenon with growing prominence in the discourse of both revenue authorities and corporate taxpayers. In the US, in-house tax professionals are now subject to unprecedented calls for transparency in terms of their tax risk management strategies and processes. This article discusses the findings of a study of these professionals conducted at a time at which the regulatory environment was becoming significantly more stringent. Overall, the evidence suggests a trend towards a more conservative approach to tax planning generally being adopted. There was also a strong message from the interviewees on the importance of the perceptions around the practice and processes on risk management. Both commonalities and differences are found in comparison with the position in the U

A conceptual map of tax rule change

Reproduced with permission from THE TAX INSTITUTE, publisher of Australian Tax Forum www.taxinstitute.com.auThe purpose of this paper is to present a conceptual map to assist tax scholars in framing their analyses of tax rule change. The map is developed in two stages; the first identifies the various factors that bring pressure to bear on the tax system to initiate rule change. The second stage observes the subsequent effect of change, or a failure to change, in terms of taxpayer response, which in turn becomes a further pressure for more change. The map is illustrated using two vignettes from different periods in time, and it is hoped that it will inspire tax scholars, from whatever disciplinary background, to embrace the complexity and hidden depths of tax as a field of enquiry

Tax professionals at work in Silicon Valley

Article in Press© 2015 Elsevier Ltd. This paper analyses a previously unexamined but nonetheless important facet of modern society - the nature and impact of the relationship between in-house tax professionals in large multinational organizations, and the external business, tax and regulatory environments within which they operate. Drawing on face-to-face interviews conducted with senior tax executives in US multinational enterprises (MNEs), we uncover the social reality of the world in which MNEs' tax executives operate, and find that these tax professionals are a powerful, elite group of knowledge experts who can significantly shape tax law and practices. We analyze the activities of these experts who, although working largely in the shadows of their organizations, are very much engaged in constructing and shaping the wider institutional environment. From a theoretical perspective that brings together institutional work and the endogeneity of law, we find these elite professionals engaging in subtle and diffuse exercise of power at a micro level within their organizations, a meso level between organizations within the field and at a macro level within the wider external environment. This has important implications for our broader understanding of the tax and regulatory environments which corporate actors inhabit

Tax Talk: An Exploration of Online Discussions among Taxpayers

AcceptedArticleWe present an analysis of over 400 comments about complying with tax obligations extracted from online discussion forums for freelancers. While the topics investigated by much of the literature on taxpayer behaviour are theory driven, we aimed to explore the universe of online discussions about tax in order to extract those topics that are most relevant to taxpayers. The forum discussions were subjected to a qualitative thematic analysis, and we present a model of the ‘universe’ of tax as reflected in taxpayer discussions. The model comprises several main actors (tax laws, tax authority, tax practitioners, and the taxpayer’s social network) and describes the multiple ways in which they relate to taxpayers’ behaviour. We also conduct a more focused analysis to show that the majority of taxpayers seem unconcerned with many of the variables that have been the focus of tax behaviour research (e.g. audits, penalties, etc.), and that most people are motivated to be compliant and are more concerned with how to comply than whether to comply. Moreover, we discuss how these ‘real-world’ tax discussions question common assumptions in the study of tax behaviour and how they inform our understanding of business ethics more generally.ESRCHM Revenue & CustomsHM Treasur

Taxing Jamaica: the Stamp Act of 1760 & Tacky's rebellion

Version published in eJournal of Tax Research © School of Taxation and Business Law (Atax), Australian School of Business The University of New South WalesIn 1760 the colonial assembly in Jamaica passed an act imposing stamp duties on the island colony as a response to increased costs in the wake of a slave rebellion. This article examines the conditions in Jamaica which led to the introduction of the 1760 stamp act, and discusses the provisions of the Jamaican act along with the reasons for its failure. This episode in eighteenth century taxation serves as a reminder of the importance of both the social context and political expediency in the introduction of new forms of taxation

The definition, measurement, and evaluation of tax expenditures and tax reliefs

Technical paper prepared for the National Audit Office © National Audit Office 2014Tax reliefs and tax expenditures are two closely related and overlapping concepts. The distinction between tax reliefs and tax expenditures is a subtle one and can only be clear after careful description of the two concepts. The first part of the report discusses how to define and categorise these concepts. Section 1 focuses upon the issue of how to define a tax expenditure and, therefore, how to distinguish a tax expenditure from a tax relief. This analysis is necessary since there is no consistency of definition in existing work or in practice. After a review of existing definitions a new definition of tax expenditures is proposed with the intention that it is useful for guiding categorisation. Section 2 reviews a number of alternative categorisations of tax expenditures and tax reliefs. Recommendations are made on the use of categorisations for the purposes of review and evaluation. The final section discusses characteristics that identify tax expenditures for review and proposes triggers for review

A population-based observational study of diabetes during pregnancy in Victoria, Australia, 1999-2008

Objectives: This paper reports secular trends in diabetes in pregnancy in Victoria, Australia and examines the effect of including or excluding women with pre-existing diabetes on gestational diabetes (GDM) prevalence estimates

INFERRING SOCIAL NETWORKS FROM PASSIVELY COLLECTED WI-FI METADATA

The emergence of smartphones and other highly portable Wi-Fi enabled devices offers unprecedented amounts of information leaked through Wi-Fi metadata. The constantly connected nature of Wi-Fi devices together with the intimate relationship between users and their device presents an opportunity for using a user’s device to gain information about the user themselves. Through passive data collection, without interference or the possibility of being detected, it is possible to harvest large datasets. This work looks at the possibility of inferring underlying social networks through the analysis of these metadata traces. Using spatiotemporal proximity as an indicator of friendship, findings demonstrate the ability to accurately predict underlying social structures in various simulated settings