Introduction: Dealing with the Impecunious Tax Debtor
I. Offers-in-Compromise in the United States
A. Doubt as to Collectability
(i) Faith in the Tax System as a Ground to Accept or Refuse an Offer
B. Effective Tax Administration
(i) Economic Hardship
(ii) Public Policy and Equity
C. Terms and Conditions: Payment and Compliance
II. Room to Manoeuvre in Canadian Law
A. Payment Arrangement
B. Taxpayer Relief: Interest and Penalties
(i) Extraordinary Circumstances
(ii) Actions of the CRA
(iii) Inability to Pay and Financial Hardship
C. Remission Orders
D. Bankruptcy
III. The Case for Compromise in the Canadian Context
A. Improving the Equity of an Inevitably Inequitable System
(i) Ability to Pay in the Canadian Tax System
(ii) Ability to Pay in the Offer-in-Compromise Program
B. Collecting More of the Tax Assessed Under the Statute
C. Compromising with Tax Policy Goals in Mind
D. Responding to Concerns About Moral Hazard
E. Responding to Concerns About Accountability
Conclusion: Review of Design Considerations