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The U.S. government mandates taxpayers remit taxes through a "pay as you go" system. Research indicates employees continue to overpay interim taxes, despite the inefficiencies of this form of forced savings. Theory holds that a rational individual would choose the minimum amount of withholdings prescribed by the tax code. We adopted Kahneman-Tversky (1979) prospect theory to show that, under reasonable conditions, individuals will continue to choose excessive withholdings. This paper is not an attempt to statistically justify prospect theory however; we argue that withholdings increase when the income tax rate increases and when beforetax income increases. Our model extends the income tax withholding literature by modeling a framework to determine an optimal withholding decision for taxpayers.

The paper considers the development of the unique fiscal relationship that exists between the government of Fiji and Emperor gold mines. Over a period of 40 years Emperor has not only paid negligible amounts of taxes and royalties it has frequently been directly subsidised by the state. In 1983 the government signed the Vatukoula tax agreement which effectively gave new mines a tax holiday for over 20 years. At the time of writing, Emperor regularly declares a dividend, is profitable in comparison to similar mines and pays no corporate taxes. The tax agreement stands as unique among developing countries in terms of allowing all potential rents from the mine to pass directly to the mine owners and almost nothing to the resource owner.

The purpose of this paper is to explain the proposed Foreign Account Tax Compliance Act (FATCA) regulations released on February 8, 2012 by the US Treasury Department and the Internal Revenue Service (IRS).

The paper provides an overview of the changes to prior FATCA guidance in the proposed regulations, including the definition of a foreign financial institution (FFI), due diligence requirements to identify US accounts, procedures to verify compliance, phase‐in information required to be reported, verification procedures, definitions of FFIs that are “deemed” to meet the FATCA requirements, definition of “passthru” payments, explanation of exemptions from withholding related to certain “grandfathered obligations,” temporary relief for FFIs with non‐compliant affiliates, and a proposed intergovernmental approach to FATCA implementation through domestic reporting and reciprocal automatic exchange of information.

The paper reveals that the FATCA grew out of Congressional concern that US taxpayers were evading taxes by failing to report US‐source income on assets held abroad. The FATCA legislation left many of the details on implementation to the US Treasury and IRS. The intergovernmental framework is not a done deal. The proposed reciprocal, automatic exchange of information would be a sea change from existing US information reporting practices and is sure to be controversial.

The paper provides expert guidance from experienced financial institutions lawyers.

We investigate how different cognitive conceptualizations of reference point and tax withholdings jointly influence aggressive tax filing. We utilize a field study with responses captured from actual taxpayers immediately after filing their returns. Consistent with both prospect theory and mental accounting perspectives, we hypothesize and find evidence that more aggressive filing decisions depend on mental categorization of whether taxpayers expect a tax refund or owe additional taxes relative to their expected asset position (EAP). We find a joint and additive impact of EAP with a cognitive link made between taxes and the categorization of amounts owed. Our findings suggest that more aggressive filing behavior is found in taxpayers in a tax loss position relative to their EAP and in those that do not separately categorize taxes owing from their own resources. By highlighting the importance of EAP and the cognitive separation of taxes owed, we provide insight for revenue agencies to use cognitive framing strategies to mitigate aggressive taxpayer behavior. The cognitive framing of EAP may be influenced by the use of installment payments and tax withholdings, but also may be affected by communications that alter taxpayers' expectations of taxes owed.

The Internal Revenue Service (IRS) and various state tax agencies are likely to touch your life as a library administrator either directly or indirectly. “Wait a minute!” you say. “We're a not‐for‐profit library and do not have to pay income taxes!” Read on. By the end of this article, you may be surprised to find that some not‐for‐profit libraries should, and do, pay income taxes. In any case, there are many tax areas that you or others in your parent organization must consider when working with these government agencies.

The European Commission is attempting to harmonise taxes in the European Community but little progress has been made to date with the exception of indirect taxation. The diversity reflects the historic differences in the economic and social structures of the member states and it is shown that wide ranging fundamental differences in tax systems remain. The main differences in tax systems, rates, bases, in approach to foreign shareholders and in business incentives are described and the problems of such disparities existing post‐1992 are highlighted.

Pooled investment funds are an extremely important component of the institutional investment management business, serving as a critical tool for achieving diversification and economies of scale in a broad range of market and investment environments. These advantages have increasingly led fund sponsors to seek investors across national borders. Nonetheless, cross‐border sales of pooled funds are fraught with numerous regulatory and tax complexities. This is particularly true for sponsors seeking to tap the enormous United Slates institutional market. This paper takes a solution‐based approach in examining the complexities of selling non‐US pooled funds to US institutional investors.