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.

How much tax revenue is lost each year as a result of noncompliance? How much of this lost revenue is from the richest taxpayers? How do the rich avoid paying taxes and why does it matter? This chapter considers these basic and important questions. The answers explain our motivation for writing this book and provide a starting point for the arguments that follow. This discussion also begins to explain why this book focuses on high-end tax noncompliance as a distinct challenge for the tax system. To answer these questions, we begin by describing exactly what we mean by tax noncompliance. The discussion then presents research findings on the scope of tax noncompliance and how it is shared across the income distribution. It then explains how high-end taxpayers can often avoid paying the taxes they owe by taking advantage of strategies that are not available to low- and middle-income taxpayers. Finally, we discuss why high-end noncompliance is harmful to the tax system, and why policymakers should treat it as a pressing challenge.

This chapter turns to the structure of the tax compliance system and how it attempts to address high-end noncompliance. It begins by situating the tax compliance rules within the broader tax system. The discussion considers what they share with all tax rules and what sets them apart. The following sections begin a more detailed dive into the structure of the tax compliance system. After addressing what motivates taxpayers to comply with the tax law, the discussion considers the main components of the tax compliance system, and how these components leverage taxpayer motivations to improve compliance. With this important context on the tax compliance system established, the discussion then returns to the challenges of high-end noncompliance. The final part of this chapter describes the two most prominent approaches in current law and reform proposals. The first general approach is to increase funding of the Internal Revenue Service so it can more effectively deter noncompliance and recover unpaid taxes. The second general approach is what this book terms “activity-based” rules, targeting the specific taxpayer activities that can either indicate or enable tax noncompliance.

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.

This chapter analyses the efforts by Benin and other sub-Saharan African countries to raise tax revenue, in regard to structural characteristics, and explores possible determinants of, and the scope for, greater domestic revenue mobilisation and for tax policy and administration reforms. First, the tax effort in Benin remained relatively stable in 1980–2015, but Benin performed poorer (14th) compared to its neighbour Togo (5th). Second, there is evidence of a positive effect of government transparency and accountability, ‘control of corruption’, and political stability on tax effort. On the contrary, foreign aid is associated with low tax effort. Third, several strategies are investigated to reduce the tax gaps in Benin. If the tax policy seems relatively constrained by reference to the West Africa Economic and Monetary Unions Tax Directives, the Togolese experiment of switching to a semi-autonomous revenue authority may provide guidance to find some room to improve domestic revenue mobilisation. In particular, Benin should review the management of human resources in the tax and customs administrations, and the scope of derogatory regimes that generate tax expenditures.

This chapter identifies the book’s two basic aims: (1) explaining what policy makers and scholars interested in building tax capacity in developing countries may learn from the Chinese experience; and (2) articulating a framework for understanding the politics of taxation in China. It then explains how the unique approach of the book, which focuses on ground-level tax administration, serves these two aims. In relation to the first aim, the book will argue that contrary to assumptions in the current literature, there are fundamentally different types of state capacity in taxation, which follow potentially irreconcilable choices in the face of difficult trade-offs. In relation to the second aim, the book uses the structure of tax administration to illustrate the heterogeneity of political incentives within the Chinese state, critical information bottlenecks, and the political motives behind invocations of law. Unifying the pursuit of these two aims is a reflective conception of law as a special form of securing social order, which sees legal ordering as fundamentally different from social ordering based on state coercion. A summary of the ensuing chapters follows.