After 2015, it may be virtually impossible for foreign financial institutions (FFls) to avoid the reach of the Foreign Account Tax Compliance Act (FATCA),1 even if they have no United States presence nor any direct U.S. investments. This is because, beginning sometime after January 2015, FFls...

Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

Beyond the traditional debates over information exchange vs flat taxation at source, legislative advances have produced interesting innovations and suggestions concerning how to tax international savings. We examine some of these advances, which we then use to set forth and investigate a...