The COVID pandemic and the rise of zooming has increased the ability of many people (primarily the rich) to work remotely. This in turn has led to more people moving to other countries to benefit from the ability to work remotely while enjoying other benefits such as lower housing prices, a more...

With the election of Donald Trump and the Republican Party's domination of Congress, House Speaker Paul Ryan's blueprint for fundamental tax reform requires more careful analysis. The Ryan blueprint combines reduced individual rates with a destination-based cash flow type business tax applicable...

With the election of Donald Trump and the Republican Party's domination of Congress, it is time to seriously consider House Speaker Paul Ryan's blueprint for fundamental tax reform. The Ryan blueprint combines reduced individual rates with a destination-based consumption or cash flow type...

With the election of Donald Trump and the Republican Party's domination of Congress, it is time to seriously consider President Trump's tax plan and House Speaker Paul Ryan's blueprint for fundamental tax reform. The Trump plan lacks detail, but includes unrealistically large and regressive tax...

This paper aims to suggest two proposals for solving the current problems of the U.S. international tax regime that can be implemented on a bipartisan basis. To do so, the first section below will provide some context. The next section will survey recent reform proposals by both U.S....

Since the market is less subject to tax competition pressures than the location of headquarters or production facilities, reducing the PE threshold makes it easier to prevent BEPS. This has recently led some jurisdictions to enact new taxes aimed specifically at structures that seek to exploit...

The “Unified Framework for Fixing Our Broken Tax Code” (the “Framework”) released by the “Big Six” group of Treasury, White House and Congressional leaders on September 27 has been the focus of a lot of commentary. Most of the comments have focused on the distributive aspects of the...

On April 26, 2017, President Trump issued a one-page tax reform outline that included “territoriality,” i.e., exempting from tax dividends from the non-Subpart F income of controlled foreign corporations. Territoriality is also included in the House GOP “Better Way” Blueprint and was...