Introduction / Reuven S. Avi-Yonah & Michael Lang -- European constitutional intergration : the case of direct taxation / Gianluigi Bizioli & Claudio Sacheto -- There is life in the old dog yet : horizontal comparability and the establishment of the internal market / Michael Lang --...

ECJ direct tax cases and domestic constitutional principles: an overview / Claudio Sacchetto -- Double taxation and EC law / Michael Lang -- Nondiscrimination from the perspective of the OECD model and the EC treaty: structural and conceptual issues / Kees van Raad -- The US Supreme Court's...

The global corporate minimum tax (GLoBE) as embodied in Pillar 2 of the OECD/IF BEPS 2.0 proposal was set in October 2021 at 15% of the financial statement income of within scope MNEs. That is also the rate and the base of the new US corporate alternative minimum tax (CAMT). The Single Tax...

Any proposal for adoption of a unitary tax (UT) system ought to clear the first and most common hurdle of its compatibility, or lack of it, with the current norms in the international tax system – specifically, the current tax treaty network. This paper argues that unitary taxation is...

Overall, TRA17 is not much worse than TRA86 or TRA14. It increases the deficit, but not by an impossible amount; it is distributionally skewed, but less so than is usually assumed; and its details are not terrible (on the international side they are a big improvement over prior law). There is one...