The author argues that the Obama Administrations 2011 international tax proposals represent a very cautious first step toward making US multinationals pay their fair share of the tax burden and that coordination with our FDI partners would allow the Administration to go even further.

This Perspective explores the implications for the home countries of large MNEs of the agreement reached by over 140 countries in 2021 to enact a corporate minimum tax of 15%. It argues that the corporate minimum tax complements the trend to reduce the negative impact of unfettered globalization...

This paper compares the effective tax rates of the 100 largest US multinationals to the 100 largest EU multinationals for the period 2001-2010, based on financial disclosures. The paper finds that despite the higher US statutory rate the effective tax rates are comparable and that EU...

The U.S. is facing one of its hardest economic crises. Its economy has not recovered from the 2008 downturn, and the light at the end of the tunnel is far, far away. The government and the Internal Revenue Service (“IRS”) are seeking revenue sources in order to reduce its budget deficit....

The current tax treaty network was developed in the 1920s and 1930s in order to prevent double residence/source taxation. This kind of double taxation rarely exists any more because most countries have adopted either an exemption system or a foreign tax credit regime in their domestic...

The debate about whether to abolish deferral or to adopt territoriality has been going on ever since the Kennedy Administration first proposed ending deferral in 1961. The problem is that neither side has factual support for their argument about whether the U.S. tax system, including Subpart F,...

Imagine that a single person had been responsible for all US tax reforms enacted from 1969 to 2010. Such was the position of Seven-Olof Lodin, the former President of the International Fiscal Association. For over 40 years, Professor Lodin was the most influential voice in Swedish tax policy....

In the 1980s, the United States enacted three modifications to its taxation of non-residents that are arguably discriminatory. This paper discusses which of them were actually discriminatory and what the proper criterion for tax discrimination should be. It suggests that the key question should...