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I have chosen to discuss tax shelter disclosure for two reasons. First, I think much of the tax shelter problem is attributable to the historic lack of effective tax enforcement. Second, unlike Weisbach, I think enhanced disclosure - that is, some level of disclosure over and above that required by current law and administrative practice would contribute to improved enforcement and increase voluntary compliance. After some preliminary comments, I discuss three functions of a mandatory tax return disclosure regime. I then address some important implementation issues. I identify potentially relevant tax compliance literature, although my review of the literature has not been exhaustive. My discussion also refers to Treasury's temporary and proposed disclosure regulations and certain legislative proposals for enhanced disclosure, but I do not undertake a complete analysis of either. I refer to Weisbach's specific comments about disclosure at appropriate points in my discussion.

Publication Citation

55 Tax L. Rev. 289-324 (2002)

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Tax Law Commons