The Resource Catch-22: a principled basis for the settlement of tax appeals

Catch-22: a principled basis for the settlement of tax appeals

Label
Catch-22: a principled basis for the settlement of tax appeals
Title
Catch-22: a principled basis for the settlement of tax appeals
Creator
Subject
Language
eng
Summary
This article reviews the obstacles to the efficient settlement of tax appeals and, in particular, the paradox that, while the settlement of the tax disputes is motivated by uncertainty as to outcome, the jurisprudence suggests that settlements not based on certainty in the law are unenforceable. The article reviews the methods for settling a tax appeal before trial and comments critically on the jurisprudence requiring that settlements be "principled" and the law dealing with ministerial discretion more generally. It concludes with some suggestions for reform, principally a recommendation that the Income Tax Act be amended to provide expressly for compromising tax disputes, similar to existing measures in the United Kingdom and the United States
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 57 (2009),
http://library.link/vocab/creatorName
  • Sandler, D
  • Campbell, C
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • appeal
  • dispute resolution
  • case law
Label
Catch-22: a principled basis for the settlement of tax appeals
Instantiates
Publication
Label
Catch-22: a principled basis for the settlement of tax appeals
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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