The Conclusion emphasizes the book’s primary argument, that its proposed system of means-based adjustments to the tax compliance rules would more effectively deter tax avoidance and evasion by the rich than would reforms focused solely on increasing the IRS’s funding or on rules targeting specific potentially abusive activities. It notes that the book has provided four practical applications of this approach – as adjustments to tax penalties, penalty defenses, the statute of limitations, and information reporting – but that these examples are just the beginning. The book concludes that its analysis and new approach to tax administration should be relevant to legislators and other tax policymakers, scholars of both tax law and progressivity, and federal and state tax administrators.

The Introduction sets the stage by describing the intense focus on abusive tax avoidance and tax evasion by the rich among political figures, legal scholars, and the general public. The Introduction also describes the stakes for the tax system in addressing high-end tax noncompliance. It then provides an overview of two conventional approaches to the problem of high-end tax noncompliance: increasing IRS funding and “activity-based rules” targeting specific strategies that enable tax avoidance and evasion. The Introduction describes the book’s argument that both of these responses are incomplete solutions. It then describes the overlooked role that tax compliance rules – which govern critical aspects of tax administration and enforcement but that currently apply to all taxpayers without regard to their income or wealth – play in enabling tax avoidance and evasion by the rich. The Introduction provides a summary of the core argument and contribution of the book: that policymakers should introduce a system of means-based adjustments to the tax compliance rules for high-end taxpayers.

Policymakers face many design possibilities when implementing means-adjusted tax compliance rules. This chapter serves as the bridge from theory to legal design. We begin this transition by identifying some of the key design considerations that policymakers should take into account when attempting to introduce means adjustments to the tax compliance rules. In general, we propose means adjustments to certain tax compliance rules that favor high-end taxpayers when they are applied the same to everyone. These adjustments should also be designed to preserve core prerequisites of procedural fairness, and should also include an underpayment-based threshold to exempt less consequential tax offenses from these heightened tax compliance rules.

What are the weaknesses of the current tax compliance rules, and how can these rules more effectively address the challenge of high-end tax noncompliance? This chapter first describes the limitations of the traditional responses to tax noncompliance in the law and in prominent reform proposals. It then introduces a new approach: a system of means-adjusted tax compliance rules. As we argue, this approach can both complement the traditional responses to noncompliance and counter their limitations to build a more robust and effective tax compliance system. The final section of this chapter describes how introducing means adjustments to the tax compliance rules would not be a radically new direction for tax reform, but rather an extension and rationalization of principles that are already embedded in the current tax law.