Minneapolis, Minnesota USA · May 23-24, 2019

ARCHIVE — 2017 Agenda: Vienna, Austria

2017 Conference Agenda – Sunday, March 12th

Welcome Reception

Institute for Austrian and International Tax Law WU (Vienna University of Economics and Business) Welthandelsplatz 1, Building D3, 2nd floor 1020 Vienna, Austria

2017 Conference Agenda – Monday, March 13th

The Framework and Justification for Taxpayer Rights

A review of the sources of rights (constitutional, statutory, and administrative), the impact of tax “exceptionalism” on the rights of taxpayers, and the legal implications of status as a taxpayer in international taxation, including granting specific rights to people (and entities) who aren’t citizens or even physical residents of a country.

Panelists

Alice G. Abreu Professor of Law
Temple University Law School
Philadelphia, PA, United States

Bio
Elaine Benn Director, Central Customer Directorate
Her Majesty’s Revenue and Customs (HMRC)
United Kingdom

Bio
John Bevacqua Associate Professor & Senior Academic Advisor (International)
College of Arts, Social Sciences and Commerce - LaTrobe University Law School
Melbourne, Australia

Bio
Richard K. Greenstein Professor
Temple University School of Law
Philadelphia, PA, United States

Bio
Ian Young Technical Manager
Institute of Chartered Accountants
Bromley, United Kingdom

Bio

Moderators

Peter Essers Professor
Tilburg University Law School
Tilburg, Netherlands

Bio

Privacy and Transparency

As tax authorities acquire and share significant amounts of tax information about their taxpayers, significant questions arise as to the rights and protections taxpayers have as to the compilation, use, and sharing of this information. At what point in the process should the taxpayer be informed that the tax agency has information from another jurisdiction? On what basis, when and how will the taxpayer be able to challenge the use of that information on the grounds that it either should not have been collected or shared? What is the impact and taxpayer rights implications of information-sharing for individual and small and medium enterprise taxpayers, as opposed to large corporate entities? What is the role of the press in promoting transparency and tax compliance?

Panelists

Robert Goulder Special Counsel
Tax Analysts
Arlington, Virginia, United States

Bio
Ali Noroozi Inspector-General for Taxation
Australian Government
Sydney, Australia

Bio
Maryte Somare WU (Vienna University of Economics and Business)
Vienna, Austria

Bio

Moderators

Christopher S. Rizek Caplin & Drysdale
Washington, DC, United States

Bio

Protection of Taxpayer Rights in Multi-Jurisdictional Disputes

With the expanded exchange of information between taxing jurisdictions, there is an increased likelihood that taxpayers will face proposed tax assessments from multiple tax agencies. This panel will (1) explore what an effective multijurisdictional dispute resolution framework would look like and what fundamental rights it should incorporate; (2) analyze whether there is an effective mechanism for coordinating and resolving multijurisdictional disputes; and (3) analyze whether existing mechanisms provide adequate protection of taxpayer rights between jurisdictions and how they fit under existing human rights frameworks.

Panelists

Mary C. Bennett Partner
Baker McKenzie
Washington, DC, United States

Bio
Cora O’Brien Policy Director
Irish Tax Institute
Dublin, Ireland

Bio
Katerina Perrou Post-Doctoral Research Fellow
IBFD
Amsterdam, Netherlands

Bio
Michael Sell Taxation Directorate-General
German Federal Ministry of Finance
Berlin, Germany

Bio

Moderators

Philip Baker QC
Field Court Tax Chambers
London, United Kingdom

Bio

Access to Rights: the Right to Quality Service in an Era of Reduced Agency Budgets

As tax agency budgets are reduced even as the tax environment becomes more complex and tax agencies increasingly play a role in delivering non-tax benefits and policy, tax agency budgets around the world are being reduced. This panel will explore several developments in response to this state of affairs, including the reduction of person-to-person service in favor of digital or centralized services; the increased reliance on third parties (preparers, representatives, software providers) to navigate the tax system; and the impact of these changes on vulnerable taxpayer populations (e.g., the elderly and low income), particularly in self-assessment systems.

Panelists

Sebastian Beer Doctor, Country Economist
Oesterreichische Nationalbank
Vienna, Austria

Bio
Les Book Professor of Law
Villanova University School of Law
Villanova, PA, United States

Bio
Michael Hallsworth Behavioural Insights
United Kingdom

Bio
Matthias Kasper WU (Vienna University of Economics and Business)
Vienna, Austria

Bio

Moderators

Chris Bergin Publisher
Tax Analysts
Arlington, Virginia, United States

Bio

Challenges of Scrutineering Entities: Fireside Chat with Inspectors General, Ombuds, and Advocates

A candid discussion with overseers of tax agencies on the tension between agency and scrutineers; enhancing independence via appointment and funding protections – administrative provision or legislative; and access to agency information.

Panelists

Anders Bengtsson Swedish Tax Ombuds
Sweden

Bio
Diana Bernal Ladrón de Guevara Procuradora
Procuraduría de la Defensa del Contribuyente - Prodecon
Mexico City, Mexico

Bio
Hanyana Eric Mkhawane CEO of the Office of the Tax Ombud (Deputy Tax Ombud)
Office of the Tax Ombud
Pretoria, South Africa

Bio
Ali Noroozi Inspector-General for Taxation
Australian Government
Sydney, Australia

Bio
Nina E. Olson National Taxpayer Advocate
Internal Revenue Service
Washington, DC, United States

Bio
Sherra Profit Taxpayers’ Ombudsman for Canada
Office of the Taxpayers' Ombudsman
Canada

Bio

Moderators

Dr. Jeffrey Owens Professor
Global Tax Policy Center; Vienna University of Economics and Business, Austria
Vienna, Austria

Bio

2017 Conference Agenda – Tuesday, March 14th

Penalties and General Anti-Avoidance Rules

This panel will explore current research on the use of penalties and general anti-avoidance rules (GAAR) in tax administration from the perspectives of legal and economic theory and taxpayer behavior. What types of penalties and initiatives are effective deterrents of noncompliance? Do automatic or strict liability penalties deter or increase noncompliance? What safeguards should be in place before a penalty or GAAR is imposed or applied? With respect to what penalties should the tax agency bear the burden of proof for justifying penalty imposition? How does penalty administration affect taxpayers’ trust in the tax system?

Panelists

Christoph Kogler Assistant Professor
Tilburg University
Tilburg, Netherlands

Bio
Luigi Mittone Professor
University of Trento
Trento, Italy

Bio
Rupert Sausgruber Professor
Institute for Public Sector Economics, WU (Vienna University of Economics and Business)
Vienna, Austria

Bio
Christophe Waerzeggers Senior counsel in the Financial and Fiscal Law Unit
International Monetary Fund
Washington, DC, United States

Bio

Moderators

Erich Kirchler Professor
University of Vienna
Vienna, Austria

Bio

The Role of Intergovernmental Actors in Furthering and Protecting Taxpayer Rights: A Conversation

Today’s international tax landscape includes several actors that work across borders and are not aligned with any one government. Representatives from OECD, UN Panel of Tax Experts, etc. will discuss their roles in establishing, delineating, and protecting taxpayer rights.

Panelists

Dr. Anette Kugelmüller-Pugh Judge, Federal Fiscal Court (BFH)
Federal Tax Court of Germany
Munich, Germany

Bio
Hélène Michard Directorate-General for Taxation and Customs Union
European Commission DG Taxud
Brussels, Belgium

Bio
John Peterson Senior Advisor, International Co-operation and Tax Administration Division
Organisation for Economic Co-operation and Development (OECD)
Paris, France

Bio
Piergiorgio Valente Professor
CFE (Confédération Fiscale Européenne) President; Link Campus University
Turin, Italy

Bio
Melchior Wathelet First Advocate general
Court of Justice of European Union
Luxembourg

Bio

Moderators

Michael Lang Professor
WU (Vienna University of Economics and Business)
Vienna, Austria

Bio

Building Trust I: Transforming Cultures of Tax Agencies and Taxpayers

The culture, social norms, biases, and past and current experiences of both tax agency employees and taxpayers are key factors in achieving voluntary compliance. This panel will explore several aspects of tax agency and taxpayer culture. From the agency perspective, how does an agency transform itself from a “hunter” mentality to a more educational, collaborative approach? How does corruption (real or perceived) impact taxpayer norms of acceptable behavior?

Panelists

Henk Elffers Professor
Netherlands Institute for the Study of Crime and Law Enforcement
Amsterdam, Netherlands

Bio
Lotta Björklund Larsen Research Fellow
Department of Thematic Studies: Technology and Social Change, Linköping University
Linköping, Sweden

Bio
John Njiraini Commissioner General, Kenya Revenue Authority
Nairobi, Kenya

Bio
Attiya Waris Senior Lecturer
University of Nairobi Law School
Nairobi, Kenya

Bio

Moderators

Nina E. Olson National Taxpayer Advocate
Internal Revenue Service
Washington, DC, United States

Bio

Building Trust II: Safeguards on Tax Agency Power

The manner in which a tax agency enforces the tax laws can impact taxpayers’ willingness to comply with those laws. This panel will explore what approaches, safeguards, and protections can enhance taxpayer trust in the tax agency and perceptions of procedural justice, including transparency and accountability, burden of proof, administrative appeals and mediation, and access to pre-assessment judicial review.

Panelists

Diana Bernal Ladrón de Guevara Procuradora
Procuraduría de la Defensa del Contribuyente - Prodecon
Mexico City, Mexico

Bio
Kristin Hickman Professor
University of Minnesota Law School
Minneapolis, Minnesota, United States

Bio
Peter J. Panuthos Chief Special Trial Judge
U.S. Tax Court
Washington, DC, United States

Bio

Moderators

André Lareau Professor
Laval University
Quebec, Canada

Bio