Since 1992, new issues have arisen in international taxation--for example, taxation of electronic commerce, novel means of shielding passive income, the World Trade Organization (WTO) debate over the foreign sales corporation and subsequent passage of the American Jobs Creation Act of 2004, the...

The tax-driven expatriation of US corporations is a troubling phenomenon. In a "corporate inversion," a new foreign corporation, typically located in a low-tax or no-tax country, replaces the existing US parent corporation of a multinational enterprise (MNE). The US corporation then becomes a...