This paper argues that the collective action in Asia by its regional organizations has historically suffered from a "capability-legitimacy gap": a disjuncture between the capability (in terms of material resources) of major Asian powers to lead regional cooperation on the one hand and their...

This paper argues that the collective action in Asia by its regional organizations has historically suffered from a "capability-legitimacy gap": a disjuncture between the capability (in terms of material resources) of major Asian powers to lead regional cooperation on the one hand and their...

Rethinking developing country status at the World Trade Organization (WTO) is essential for the institution's modernization and survival. The Trump administration has recognized this challenge and is seeking changes to the flexibilities provided to developing countries. Referred to as “special...

Why do countries follow the rules they do for international taxation? Tax scholarship is increasingly using terms like hard law and soft law to explain the degree of global adherence to various tax practices. In this brief essay, I make the case that terms we use are important because they...

The extent of the information subjected to automatic exchange under the scope of cross border tax administrative cooperation is increasing day by day. Nowadays, financial accounts, non-financial categories (such as changes of domicile, immovable property acquisitions and transfers, value added...

During the course of the last 100 years, the wealthiest and most powerful nations on the planet have systematically gathered around in small groups of experts, scientific committees and working parties, under the auspices of the League of Nations and the OECD, to decide on the appropriate tax...

The IRS recently announced that its mandatory registration regime for paid tax return preparers, struck down in the Loving decision, would henceforth be offered as a voluntary program. But the authors of this program appear to have forgotten that the US system is perfectly global in reach,...

Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore...

Discourse on the merits and pitfalls of multilateral cooperation for advancing justice in international tax law have recently re-emerged in the literature. Some tax scholars, even while criticizing global projects like the OECD/G20 initiatives on base erosion, profit shifting and the tax...

The United States enacted a tax reform in 2010 known as the Foreign Account Tax Compliance Act (FATCA), which will impose an extensive third-party monitoring and disclosure regime on financial institutions around the world in an effort to “smoke out” American tax cheats and expose their...