All posts by May Hen

PhD student at University of Cambridge.

“An Intra-Disciplinary Approach To Taxation Research” by Dr Amir Pichhadze

This week, Dr Pichhadze will be identifying and explaining the necessary role of an intra-disciplinary approach to taxation research and analysis. He will use the example of the ‘transfer pricing’ rules, to demonstrate the need for such an approach in delineating transactions. Dr Pichhadze will argue that a tax rule can be applied to a transaction only after the transaction has been correctly delineated. A risk arises in practice that contractual terms may not be correctly analysed by tax jurists, unless they are alert to the need for an intra-disciplinary approach.

ABOUT

Dr Pichhadze is a prolific and energetic thinker in the field of Tax Law. In addition to his undergraduate LLB , he holds an LLM in Taxation from the London School of Economics and an LLM in International Taxation from Michigan Law School, where he also attained his Doctorate. Alongside his extensive academic writing, Dr Pichhadze has been an editor and a referee for numerous law journals. Away from academia Dr Pichhadze has held a Judicial Clerkship at the Tax Court of Canada. Dr Pichhadze is also a talented artist who has received numerous commissions for his work.

See “Meetings” tab for more information. We hope you will join us Thursday March 4th from 17:00-18:00 (GMT). The meeting will be held ONLINE. E-mail May Hen-Smith  hmh46@cam.ac.uk or Guy Mulley gevm2@cam.ac.uk for link

“Tax, The Constitution and Public Law” By Dr Dominic de Cogan

This week we are delighted to have Dr. Dominic de Cogan present his work to our group. As most of you may know, Dominic conceived of and co-founded the Cambridge Tax Discussion Group in October 2015 which eventually formed in to a PhD-student led group. We have been running since then with Dominic’s support and have used the forum to provide thoughtful, cutting-edge and engaging discussions on tax related topics at a very high level; and made accessible to all throughout the University and beyond. Please join us this week in what will be an engaging look at tax from a constitutional and public law perspective.

Summary of talk: Dr Dominic de Cogan, from the Faculty of Law at the University of Cambridge, will give a presentation on “Tax, The Constitution and Public Law”.    Author of Tax Law, State Building and the Constitution, Dominic will be expanding on his 2020 monograph, to address some topical aspects of the discourse on the relationship between tax and the State. From domestic issues, such as devolution in the United Kingdom, to international concerns, such as the taxation of multi-national corporations, Dominic will be challenging our established perspectives. Dominic will also be explaining his current work about the relationship between tax and public law.

See “Meetings” tab for more information. We hope you will join us Thursday February 18th from 17:00-18:00 (GMT). The meeting will be held ONLINE. E-mail May Hen-Smith  hmh46@cam.ac.uk or Guy Mulley gevm2@cam.ac.uk for link

“A Career In Tax Disputes?” presented By Robert Hartley

This week on the Cambridge Tax Group we have a presentation by Robert Hartley. We will begin at our normal time of 17: 00 on Thursday February 4th. We hope you will join us.

Please contact Guy Mulley (gevm2@cam.ac.uk) or May Hen-Smith (hmh46@cam.ac.uk) for access to the meeting link.

Title: A Career In Tax Disputes?

Robert Hartley takes a practical look at tax disputes in the UK over the last twenty years and how tax disputes progress from initial enquiries to resolution. The talk will touch on matters such as developments in the way HMRC approach tax avoidance, evidential issues such as privilege, and the human cost of unresolved tax disputes. This talk is ideal for anyone looking to gain some insight into what a career in tax looks like, or who is considering a career specialising in contentious matters more generally.

Robert Hartley is a partner and solicitor-advocate in the tax disputes team at the (hopefully) well-known firm of Mishcon de Reya LLP. Having graduated from Magdalene College in 1993, he joined the post-graduate Cambridge LLM course the same year. He then worked for a time as a junior barrister before beginning a tax career in 1999 at what is now Hogan Lovells LLP. Alongside his work on a number of high-profile contentious and non-contentious tax matters over the years, he spent a number of years teaching VAT at King’s College London, and specializes in “big ticket” direct and indirect tax disputes. He is not an accountant, but he will work with spreadsheets if he really has to.

“Toward a Fiscal Sociology of Colonialism” by Kyle Willmott

The Cambridge Tax Discussion Group is a PhD student run meeting group with weekly discussions of wide-ranging tax-related topics. We have been meeting weekly during term-time since 2015 and hope to continue with engaging topics that are tax or tangentially tax-related topics! This term, we are meeting fortnightly. We are friendly, open to all and interdisciplinary. We sincerely hope you will join us on our next online meeting which will be on Thursday 21 January at 17:00-18:00 (GMT). See our “Meetings” page for updated talks, links and previous topics covered.

This week’s talk can also be found on talks.cam along with an assortment of university-wide talks: http://talks.cam.ac.uk/talk/index/156064

Abstract: The presentation examines the strategic role of tax in relation to Canada’s colonial administration of Indigenous nations and the broader role of tax in relation to settler colonialism. I will discuss some of the ongoing analytical problems in tax scholarship in relation to colonialism and look to build an approach that focusses on the informal and ideational life of tax. The case study examines the First Nations Financial Transparency Act, which paired ideas about transparency with taxation, accountability, and citizenship. I aim to show how the state bureaucracy aimed to re-make Indigenous political identity around ‘taxpaying’.

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About Our Presenter

Kyle Willmott is Assistant Professor of Sociology at Simon Fraser University in Vancouver, British Columbia, Canada. Working between political sociology, fiscal sociology, and economic sociology, his research attends to the cultural politics of taxation, Indigenous-settler relations, settler colonialism, and liberalism. His work has been published in Economy and Society and Critical Social Policy. He is Mohawk from the Mohawks of the Bay of Quinte First Nation.

More information, including a link to the meeting, can be found here: http://talks.cam.ac.uk/talk/index/156064

Researching Tax from Four Copenhagen Business School scholars

This week we have four special guests from Copenhagen Business School who will be introducing and discussing their work in tax from three different fields of research. With thanks to Yvette Lind who has co-ordinated this group of speakers for what will be a very engaging discussion on tax but also three approaches to studying tax. We will begin an hour earlier than normal on Thursday October 29th at 16:00-17:00 London time and, as always, all are welcome to attend.

Updated information on this talk and other talks at the University of Cambridge can be found here.

SPEAKER BIOGRAPHIES

Karen Boll is Associate Professor at Copenhagen Business School. Karen conducts ethnographic and qualitative studies of tax authorities’ work, business’ tax compliance practices and collaborative tax regulation. Karen’s work has been innovative in seeing tax compliance as an assemblage of relations and actors, and groundbreaking in her access to studying tax administration in both Denmark and Sweden. Karen’s work on taxation has been published extensively in journals such as Journal of Organizational Ethnography, Nordic Tax Journal, Critical Perspectives on Accounting, Journal of Cultural Economy, Journal of Tax Administration and Accounting, Organizations and Society.

Yvette Lind is currently an Assistant professor in tax law at Copenhagen Business School (CBS Law). Swedish jur.dr. (JD) specializing in international taxation with an emphasis on challenges arising from globalization, increased taxpayer movement and the fragmentation of law. Awarded Swedish TOR/Skattenytt post-doc between 2017-2019 in connection to defending her doctoral thesis, facilitating specialising in EU state aid law in various fiscal contexts, e.g. tax avoidance and environmental taxation. Currently working on her taxation and democracy project in which she explores the effects of increased taxpayer mobility with reference to the allocation of not only taxation and access to (social) welfare benefits but also political rights and benefits such as voting privileges. Regular guest researcher and teacher at the Faculty of Law, Lund University.

Saila Stausholm is a doctoral student at Copenhagen Business School, currently finishing her dissertation on the International Political Economy of international taxation, through the Horizon 2020 project COFFERS “Combating Fiscal Fraud and Empowering Regulators”. Stausholms research spans different dimensions of the political economy of corporate taxation and exploits new datasources on hard-to-study phenomena.Her projects have identified the role of transnational professionals in offshore finance through mapping the geography of tax advisors and Big Four accounting firm employees, investigated the effectiveness of tax incentives in developing countries, and estimated the revenue impacts of a global reform of corporate taxation towards destination based cash flow taxation.

Leonard Seabrooke is interested in the micro-level elements that permit the macro composition of the international political economy and transnational governance. This includes: how professionals compete and coordinate to establish new regulations and new markets; the professional careers of those involved in international economic governance and transnational activism; generational conflicts between groups seeking to secure housing and financial assets within different national systems of residential capitalism; and conflict between groups over taxation and accounting issues. His work frequently draws upon analytical and methodological tools from political economy and economic sociology, including sequence analysis and social network analysis, among others.

To access the meeting, use this link

Or, if you email gevm2@cam.ac.uk, Guy will send you a link to this and all future meetings via Teams/Outlook Calendar.

Best wishes

May Hen-Smith and Guy Mulley

Co-convenors, Cambridge Tax Discussion Group

Mini presenTations by tax scholars

During this term we will meet fortnightly. For this week’s meeting we will be able to hear about tax research across the academic spectrum and from around the world. For information on upcoming and past meetings click on our “UPCOMING MEETINGS” tab.

We have five mini-presentations:

  • Professor of Law Neil Buchanan, from the University of Florida, will be explaining how he chooses topics for scholarly writing, how theoretical research advances the conversation and how to deal with economics in tax analysis.

  • Philip Baker QC, tax barrister and a visiting Professor, will be discussing the practising lawyer’s approach to academic tax law and the role of practicing lawyers who also engage in academic work, as well outlining his own journey into tax academia and some of his current research plans.

  • Dr Amir Pichhadze, from the University of Oxford, will be bringing his international academic experience to bear on the subject of tax law teaching and research.

  • Christina Allen, lecturer in law at Edith Cowan University in Perth, Australia, will be using her forthcoming tax project about definitions of wealth and income to illustrate the challenges of framing and narrowing a research question.

  • Gabriel Nwodo, a Nigerian law graduate, will be articulating why he is returning to academic study, as a newly arrived LLM postgraduate student at the University of Cambridge.

As usual, there will be the opportunity for discussion and asking questions.

The one-hour meeting will be start at 5:00pm British Summer Time. If you would like a calendar invitation sent to you via Teams/Outlook, please email gevm2@cam.ac.uk . Otherwise, the link for the meeting is here:

https://teams.microsoft.com/l/meetup-join/19%3ameeting_MDRmNzY0NjctMTc5NS00OTA4LWE4ZWYtYTU5ZTI4MThmYTcw%40thread.v2/0?context=%7b%22Tid%22%3a%2249a50445-bdfa-4b79-ade3-547b4f3986e9%22%2c%22Oid%22%3a%22cce22f0f-bf2a-4e51-beb7-cf129dbab444%22%7d

We look forward to seeing you at the meeting.

Best wishes,

May Hen-Smith and Guy Mulley

Co-convenors, Cambridge Tax Discussion Group

“Where’s the Money Coming From? How Tax and Spending Debates frame Electoral Politics” By Peter Sloman

Please join us online this week to engage with Dr. Peter Sloman of POLIS, University of Cambridge on Thursday September 17th, from 17:00-18:00 (BST) ONLINE (e-mail hmh46@cam.ac.uk or gevm2@cam.ac.uk for link).

Peter will be discussing the following topic: “Where’s the Money Coming From? How Tax and Spending Debates frame Electoral Politics”

Abstract: Tax and spending are central to democratic politics in the UK and elsewhere, but political scientists have paid surprisingly little attention to the practice of manifesto costings or the ways in which fiscal promises shape voting behaviour. This paper explores how British parties have used manifesto costings to frame prospective choices for voters since the 1950s, and develops a theoretical framework for understanding why warnings about ‘tax bombshells’ and ‘black holes’ in parties’ spending plans seem to be so powerful in Westminster democracies such as the UK. Whereas retrospective evaluations of economic performance can be difficult for governments to control, forward-looking fiscal debates are structurally weighed towards incumbent parties. Other constitutional structures may have very different implications for the role of public opinion in the tax policy-making process.

Peter Sloman is University Senior Lecturer in British Politics at POLIS and a Fellow of Churchill College. Before joining POLIS in 2015 he spent ten years in Oxford, where he was a student at Queen’s and a junior research fellow at New College.

Peter’s research focusses on political ideas, public policy, and electoral politics in modern Britain. His first book, The Liberal Party and the Economy, 1929-1964 (Oxford, 2015) explored how British Liberals engaged with economic thought in the era of John Maynard Keynes and William Beveridge. His second book, Transfer State (Oxford, 2019), examines how changing attitudes to work and social welfare have shaped the development of Universal Credit and the campaign for a universal basic income.

“Taxing Capital Appreciation for Fairer Taxation, Constitutions and a Comprehensive Tax Base” by Professor Henry Ordower

The Cambridge Tax Discussion Group is a PhD student run meeting group with weekly discussions of wide-ranging tax-related topics. We have been meeting weekly during term-time since 2015 and hope to continue with engaging topics that are tax or tangentially tax-related topics! We are friendly, open to all and interdisciplinary. We sincerely hope you will join us on our next online meeting which will be on Thursday 2 July at 17:00 (British Summer Time). See our “Meetings” page for updated talks, links and previous topics covered.

This week’s talk can also be found on talks.cam along with an assortment of university-wide talks: http://www.talks.cam.ac.uk/talk/index/149806

This week, Professor Henry Ordower, from Saint Louis University, will be discussing tax fairness in an international context, under the title: “Taxing Capital Appreciation for Fairer Taxation, Constitutions and a Comprehensive Tax Base”. Further details are below.

We look forward to seeing you on Thursday.

May Hen-Smith and Guy Mulley Co-convenors, Cambridge Tax Discussion Group

ABSTRACT

The presentation will start with a brief exploration of the realization question in the pending constitutional challenge to the peculiar US transition tax (IRC 965) and then contextualize the historical issue of realization and income and the comprehensive tax base. I will consider some of the justifications for a realization requirement and preferential treatment of capital gain and contrast them with some economic drawbacks to a realization-based system. The presentation will move to mark to market (with its trade-offs to overcome objections), the gradual abandonment of realization in the US and conclude by considering distributional fairness under a realization-based

BIOGRAPHY

2017 Marketing ShootHenry Ordower is Professor of Law at the Center for International and Comparative Law at Saint Louis University. His recent research has focussed on issues of tax distribution and the growing disparity of wealth between individuals. In addition to his academic research and teaching, he runs a tax consulting practice and he provides expert testimony in complex tax litigation matters. An avid traveller and linguist, Professor Ordower has visited more than 100 countries.

“The new politics of global tax governance: What the past tells us about the future of international taxation” by Rasmus Christensen

 

This week we have an exciting talk by Rasmus Christensen on the politics of tax governance. We sincerely hope you will join us online on Thursday, 18th of June at 15:00-16:00 (British Summer Time). See our “Meetings” page for updated talks, links and previous topics covered. Please e-mail May at hmh46@cam.ac.uk or Guy at gevm2@cam.ac.uk for link asssistance.

This week’s talk can also be found on talks.cam along with an assortment of university-wide talks: http://www.talks.cam.ac.uk/talk/index/149563

“The new politics of global tax governance: What the past tells us about the future of international taxation”

Abstract

The past decade has revealed that systemic change is underway in the foundations of global tax politics, entangled with changes in global politics at large. States are more aggressive in cracking down on tax havens, and cooperating more effectively through multilateralism. Global power is shifting towards large emerging markets. Media attention and focus on inequality has fueled unprecedented discontent with international tax rules. And the digital economy is ripping historical alliances apart, creating new battles lines in global tax negotiations.

Description: Based on a recently published paper (with Martin Hearson), in this talk I set out how these global trends indicate a radical departure from the stable past of international tax, and how they are shaping ongoing discussions to change the system, at the OECD and beyond. As the international tax system stands at a historical crossroads, finding new balances – on inclusiveness, coherence, and legitimacy – will be key to developing a sustainable international tax system for the future.

Rasmus Corlin Christensen , maj 2017Rasmus Corlin Christensen is a political economist at Copenhagen Business School and a research associate at the International Centre for Tax and Development. His research focuses on processes of change in the politics and professional practice of international taxation. He has been recognized as an influential individual in the global tax world, being named to the International Tax Review´s “Global Tax 50” in 2017. You can find him at phdskat.org or @phdskat

“The Village Of Billionaires: An Examination Of The Paradox Of Relative Poverty” By Dr. Alexis Brassey and Professor Henry Ordower

The Cambridge Tax Discussion Group is a PhD student run meeting group with weekly discussions of wide-ranging tax-related topics. We have been meeting weekly during term-time since 2015 and hope to continue with engaging topics that are tax or tangentially tax-related topics! We are friendly, open to all and interdisciplinary. We sincerely hope you will join us on our next online meeting which will be on Thursday 11 June at 17:00 (British Summer Time). See our “Meetings” page for updated talks, links and previous topics covered.

This week’s talk can also be found on talks.cam along with an assortment of university-wide talks: http://www.talks.cam.ac.uk/talk/index/148804

This week, Dr Alexis Brassey, from the University of Cambridge, and Professor Henry Ordower, from Saint Louis University, will be discussing tax fairness in an international context, under the title “The Village Of Billionaires: An Examination Of The Paradox Of Relative Poverty”. Further details are below.

We look forward to seeing you on Thursday.

May Hen-Smith and Guy Mulley Co-convenors, Cambridge Tax Discussion Group

ABSTRACT

Tax justice and principles underpinning the international tax regime are in vogue. The idea that companies and individuals need to pay their “fair share”, not just in the domestic sense but also the international sense, is now a mainstream position. This paper explores the problems relating to what might constitute a “fair share” by setting out what is meant when this expression is used. A reasonable assumption is to consider taxation as the means by which the state funds public services and in some jurisdictions, contributes to greater equality within society. Those goals, however, give rise to competing claims. This is especially the case when considering international tax challenges, for example those faced by the OECD ’s 2019 work plan. This paper, in examining competing claims for tax revenues, considers the specic categories of relative as opposed to absolute poverty. If one accepts that taxation is to fund public services, the question arises, at least in international tax, which jurisdiction’s public services? If the motivation for raising tax is to tackle inequality, what has the greater claim, international inequality or national inequality? It is in answering these questions that we need to address the issue of which is more pressing, relative as opposed to absolute poverty? The contention in this paper is that there is a far stronger moral claim for tax to be redistributed on an international basis rather than on a nation basis. Further, this paper contends that purported moral claims which seek to address inequality within national borders are merely political demands made to further the economic interests of particular groups who themselves are amongst the most economically privileged, when viewed on an international spectrum. The article is designed for those progressive or communitarians who strongly advocate for redistribution within national boundaries. It is not designed to appeal to those of a libertarian perspective.

BIOGRAPHIES

alexis-2_cutout_do-not-save-copy-485x302Dr Alexis Brassey is a Solicitor and a Visiting Fellow of the Centre for Tax Law at the University of Cambridge. He holds an MA in Philosophy, an LLM in Corporate Law and a PhD in Psychology, as well as a PhD in Law. His research in Tax Law encompasses tax avoidance, constitutional law, tax fairness and jurisprudence. He has also worked in investment banking.

2017 Marketing ShootHenry Ordower is Professor of Law at the Center for International and Comparative Law at Saint Louis University. His recent research has focussed on issues of tax distribution and the growing disparity of wealth between individuals. In addition to his academic research and teaching, he runs a tax consulting practice and he provides expert testimony in complex tax litigation matters. An avid traveller and linguist, Professor Ordower has visited more than 100 countries.