The Demise of the “Near-Sole Shareholder” Doctrine and the Emerging Problem of Sham Multi-Member Structures …
The doctrine of undisclosed sources of income represents one of the most far-reaching powers available to…
In dubio pro tributario (Lat. “when in doubt, in favor of the taxpayer”; Ger. Zweifel zugunsten…
I. Introduction Many entrepreneurs regard the principle of in dubio pro tributario as a trump card…
I. Introduction: The Tension Between Fiscal Efficiency and Financial Privacy Few questions in modern tax law…
Poland built an algorithm to catch tax cheats. It works—except when it doesn’t. On a Monday…
For nearly five years, the tax authority pursued fruitless enforcement proceedings against a company’s assets —…
Polish Courts and the Expanding Doctrine of Manifest Unconstitutionality How the Kielce Administrative Court’s 2023 Ruling…
Statute of Limitations for Tax Obligations (Ger. Verjährung von Steuerschulden; Fr. prescription fiscale) – The statute of…
When the Fisc Buys Time The statute of limitations on tax obligations constitutes one of the…
Tax audits and regulatory inspections of business operations constitute among the most burdensome forms of state…
The New Mexico trial that could redefine what Big Tech owes children On Monday morning, in…
I. Introduction The Value Added Tax (VAT) stands as the preeminent instrument of indirect taxation across…
Running separate businesses by spouses under a statutory community property regime is a common phenomenon in…
Preferential Tax Treatment Under Polish Law and the Approaching 2026 Legislative Reform I. Introduction Equity-based and…
The Holy Grail Myth: Hashing, Pseudonymization, and the Evolving Boundaries of Personal Data Protection For over…
Inside the trial that could redefine what ride-hailing companies owe their passengers—and what they’ve known all…
Confidentiality Clauses and the Right to Legal Counsel: The Boundaries That Non-Disclosure Agreements Cannot Cross In…
The Problem of Discrepancies Between Numerical and Written Expressions I. Introduction: When Numbers and Words Collide…
I. Introduction: The Deceptive Simplicity of Silence Consider the following scenario: a commercial enterprise transmits an…
Genesis allocation—the initial distribution of tokens created contemporaneously with the establishment of a new blockchain network—presents…
Theoretical Foundations, Comparative Systems, and Contemporary Challenges I. Introduction The property tax—denominated Grundsteuer in German fiscal…
Theoretical Foundations, Comparative Frameworks, and the Regulatory Challenges of Decentralized Finance Cryptocurrency taxation encompasses the corpus…
Regulatory Frameworks, Compliance Architectures, and the Challenge of Decentralized Finance The proliferation of blockchain technology and…
I. Introduction Cryptocurrencies constitute a novel class of digital assets employing asymmetric cryptography to secure transactions…
I. Introduction The participation exemption—known variously as Schachtelprivileg in German jurisprudence, exonération des dividendes in French…
In December 2025, the Regional Administrative Court in Olsztyn rendered a judgment that may significantly reshape…
Related parties (also termed affiliated entities or associated enterprises) constitute business entities maintaining mutual capital, personal,…
How a Google Engineer Spent His Lunch Breaks Google employs thousands of security engineers. Spends billions…
What a London arson trial reveals about Russia’s intelligence doctrine—and the West’s dangerous misreading of it…
