Document Type


Publication Date

Winter 2013

Publication Citation

20 Indiana Journal of Global Legal Studies 449 (2013)


Globalization diminishes the U.S. government's ability to enforce the income tax by undermining the Internal Revenue Service's information advantage. U.S. taxpayers are able to hold their money overseas, where the IRS's information-gathering abilities are at their lowest ebb, with increasing ease. Tax treaties aim to rectify the IRS's information disadvantage abroad by encouraging foreign countries, particularly tax havens, to share information with the IRS. However, these treaties have been largely ineffective. Instead, it may be time for the United States to go the way of other developed countries and reform its tax structure to reduce reliance on the income tax and adopt, instead, a value-added tax.