October 21, 2013
4:15 - 5:15 p.m., Room 236 Hutchins Hall
"What Goes Around Comes Around: How the US Aided World Tax Evasion and What It Can Do About It"
Professor Reuven S. Avi-YonahThere are, of course, a lot of ways that the U.S. policies have rewarded persons playing offshore tax games. Some have traditionally been viewed as implicating only civil consequences. These include transfer pricing and such other shenanigans that, if not too egregious, are simply subject to civil adjustment and perhaps some civil penalties. But the title of the article seems to focus on evasion which is commonly meant to be the conduct that draws criminal sanctions. Professor Avi-Yonah is a frequent speaker and author on international issues, so his work product is likely to be if interest to readers. I will post further on this, particularly as is likely if he writes an article or outline than can be linked for readers' review.
Irwin I. Cohn Professor of Law, University of Michigan Law School
Professor Avi-Yonah's bio is here.
Addendum 10/22/13 1:15pm:
Professor Avi-Yonah advises that the following paper is the one used for this address: Avi-Yonah, Reuven S., What Goes Around Comes Around: Why the US is Responsible for Capital Flight (and What it Can Do about It) (January 23, 2013). U of Michigan Public Law Research Paper No. 307. Available at SSRN: http://ssrn.com/abstract=2208553 or http://dx.doi.org/10.2139/ssrn.2208553. The paper is here. The paper is a good short introduction to the history through FATCA, concluding:
The US learned the hard way that trying to attract foreign capital by not withholding and not collecting information is a recipe for undermining US taxation of Americans. FATCA now offers a way forward to cooperate with other countries that wish to tax their wealthy residents on all income “from whatever source derived.”