There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as...

The 2017 US tax legislation - widely referred to as the Tax Cut and Jobs Act (TCJA) - fundamentally transformed the US system of international taxation. It ostensibly ended worldwide taxation but introduced, for instance, a new tax on "Global Intangible Low-Taxed Income" (GILTI). This paper...

This article examines some of the background to the 1954 Japan-United States Income Tax Treaty from a historical perspective.Japanese domestic law developed the “source” of income concept and implemented a foreign tax credit system during the three years of treaty negotiations. The 1954...

The problems of tax evasion and tax avoidance are as old as taxes themselves. Between 2015 and 2016 alone, many U.S. multinational corporations were involved in tax disputes with the European Commission. From a historical perspective, these disputes are unprecedented as they have resulted in...

These slides were prepared for lectures I gave at law schools in Shanghai and in Israel the week of November 13, while the Tax Cuts & Jobs Act of 2017 (H.R.1) was under active consideration in the U.S. House of Representatives and the Senate version of the Tax Cuts and Jobs Act was being...

This paper sets forth a simple, but potentially infinitely expandable, model through which the consequences of changes in U.S. international tax rules can be explored. The question it poses is straightforward: Assume that our task is to aggregate funds from taxable U.S. or foreign individual...

This paper — prepared for a symposium held at Brooklyn Law School on October 23, 2015 on Reconsidering the Tax Treaty — addresses the treaty compatibility aspect of proposals for reforming the U.S. international tax system. Finding that a reform proposal is treaty compatible obviates the...