Authors

William Byrnes

Document Type

Essay

Publication Title

Emory Int'l L. Rev. Recent Dev.

Publication Date

Spring 1-1-2017

Abstract

Professor Byrnes offers a preliminary narrative to examine the serious challenge of Control Firsters' vision that every jurisdiction should have complete information on all transactions by any taxpayer. A question that Control Firsters must address is whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International's corruption index. Quite possibly, the complete information system invoked by Control Firsters encourages, even prolongs, the bad behavior by providing fuel (financial information) to feed the fire of corruption and suppression of rivals. In light of this, Professor Byrnes recommends that the United States leverage a 'carrot-stick' policy tool to incentivize bad actors to adopt best tax administration practices by offering reciprocal automatic exchange of information via the Foreign Account Tax Compliance Act (FATCA) Competent Authority Agreements.

Volume

31

First Page

1033

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