COMPARATIVE TAXATION
MATERIALS FOR THE SEMINAR
Tax
Law Design and Drafting
by Victor Thuronyi (IMF 1998).
Selected
pages of Comparative Income
Taxation - A Structural Analysis by Hugh
J. Ault will be distributed in class throughout the semester.
Additional materials will be distributed periodically. Weekly assignments will also appear on the "Assignment" page of the Webcourse.
The seminar has been designed with a view to
facilitating your successful completion of a traditional type of seminar paper
instead of an exam in order to satisfy an advanced writing requirement. I shall
be happy to discuss possible projects with you. The written requirements of the
seminar will be the basis of 75% of your grade in the seminar.
Each student's work on the course paper will consist of four submissions, not later than the dates below:
February 13: One page description of paper topic
February 27: Outline of paper and list of sources
March 20: First draft of complete paper
April 29: Final Paper Due (with sources)
CLASS PROCEDURES
The success of any seminar depends primarily upon the
contributions of its members. Since we shall meet as a seminar, each of you is
expected to carry a substantial responsibility for advancing our discussion and
understanding. You will periodically be asked to undertake particular tasks with
respect to various problems or exercises. Even if you do not have an assigned
role, however, you will be expected to participate in seminar discussion and
debate.
Many of the responsibilities for class presentations
will be assigned to individual students. In addition, we will periodically have
guest lecturers join us from the private sector.
There is always a chance that illness or other
circumstances will cause you to miss a session or to come without full
preparation. Each of you may have one "bad day" during the course of
the semester. If you advise me in advance of the session, your absence or
failure to participate will not bear any adverse consequences.
Class participation will account for 25% of your grade in the seminar.
PREREQUISITES AND RECOMMENDATIONS
Tax I is a prerequisite for this course. We shall often be dealing with rules that constitute specific applications of or exceptions to the principles that you have studied in Tax I.
ASSIGNMENTS
Class #1:
Introduction to
Course Lecture
READ:
Introductory Material (Ault Handout) pages 1-3.
"General Description: United States" (Ault Handout) pages 131-154.
Class #2:
Reread
Ault Handout pages 137-154.
READ:
Ault pages 40-41; 192-201 (Capital Gains)
Taxation of Capital Gains in Selected Countries
89 TNI 44-6 (1989)
READ:
General description of your chosen country in the Ault book and be prepared to
present it to the class. The Hugh Ault book is available on reserve in the
library.
Class
#4:
READ:
Ault Handout: 285-305;
Bush
Shareholder Relief Plan:
READ:
Treasury Report on Dividend Proposals
("Bluebook");
Sheppard article in Tax Notes
Presentations:
Read Tax policy in the European Union
Class
#5:
READ:
Sheppard article in handout area
Tax Law Design p 811-829 and p 840-864
Skim Ault description of Australia
ONE PAGE DESCRIPTION OF PAPER TOPIC DUE
Class #6:
READ:
Tax Notes International article on Top Tax Rates
in OECD Countries: A New Look
SKIM:
Ault description of Canada & Germany [in handout
area]
Presentations:
Class #7:
READ:
Ault Handout: 368-385 (Be Prepared to Discuss how
your Country Classifies People as Residents)
Tax Law Design pages 718-721, 729-732, 734-749
Electronic Commerce:
READ: Tracy A. Kaye, The U.S. Perspective on Electronic
Commerce;
Jones and Basu, Taxation of Electronic Commerce: A
Developing Problem International Review of Law Computers & Technology
Sandra P. McGill & Lowell D. Yoder, From
Storefronts to Servers to Service Providers: Stretching the Permanent
Establishment Definition to Accommodate New Business Models, Taxes (March
2003).
Skim U.S. Taxation of Profits from Internet Software Sales
-- An Electronic Commerce Case Study. & Selected Tax Policy Implications on
Global Electronic Commerce [located in Course Documents]
OUTLINE
OF PAPER AND LIST OF SOURCES DUE
NO CLASS: March 6
SEMESTER BREAK -
NO CLASSES.
Class #8:
Tax Evasion
READ:
David Cay Johnston, Bush Budget Increases Push to
Find Tax Cheats , N.Y. TIMES Feb. 5, 2003
Hunting
Tax Cheats, I.R.S. Vows to Focus More Effort on the Rich , N.Y. Times
Steve Holub, Tax Fraud and Tax Protestors ,
The Tax Adviser (Dec. 2002).
Class #9:
READ:
Tax Law Design pages 537-542
FIRST DRAFT OF COMPLETE PAPER DUE
Class #10:
READ:
Tax Law Design 547-550
Class #11:
READ:
Tax Expenditures in the 2004 Budget [link available
in course documents]
Presentation:
Class #12:
READ:
Tax Competition in Europe: General Report by
Prof. Dr. Wolfgang Schon
Presentations-
Class #13:
Class replaced by Lexis and Westlaw Training earlier in the semester
Class #14:
NO CLASS
Class
#15:
FINAL
PAPER DUE
READ
:
Sven C. Oehme, An Overview of the European Union,
its Legal Structure and its New Currency , New Jersey Lawyer (Feb. 1999);
Terra & Wattel, EUROPEAN TAX LAW pages
36-66.