ABSTRACT

This chapter focuses on the different cultural and constitutional positions and suggests that the constitutional history of the US informs a cultural attitude to taxation which is different from that in the UK, and whose absence may well affect compliance in the UK. The chapter explains, so far as concerns the United States, that constitutional history must be considered as providing a backcloth against which self-assessment operates. It introduces the technical uncertainties and vigorous enforcement mechanisms of American self-assessment, some of which may prove problematic in the UK. To locate tax in an American constitutional context, the chapter engages in a brief nod towards its English roots. The origin of the income tax has been traced back to the times of Henry II. The concept of taxation as means of funding the government, however, was antithetical to the times of Edward I. Relations were tense between Charles I and Parliament from the start.