Every nation has an interest in sharing the gains they help create by participating in globalization. If governments fail to claim an adequate share of these gains, they will be forced to look ever more intensely to personal taxes on their own already-burdened citizens. Yet because of the...

This essay makes a proposal that might be controversial among tax scholars even if it is non-controversial to those with a particular interest in international law: that international social and institutional structures shape, and are shaped by, historical and contemporary domestic policy...

In its first term, the Obama administration enacted two pieces of legislation, each designed to protect an increasingly vulnerable income tax base, and each of which had the potential to set a new and unprecedented course for no less than the regulation of the global economy by the nation-state....

Tax scholarship typically presumes the state’s power to tax and therefore rarely concerns itself with analyzing which relationships between a government and a potential taxpayer normatively justify taxation, and which do not. This paper presents the case for undertaking such an analysis as a...

A group of journalists recently revealed “LuxLeaks”: a set of documents showing that Luxembourg’s tax authority has been systemically delivering secret deals to multinationals. In this column, I explain why LuxLeaks has revealed a feature, not a bug, in the international tax system....

Some countries are undertaking, and others considering, self-examination rules to detect whether proposed tax reforms might have a negative impact on tax policy or economic outcomes in less affluent countries. The impetus for this kind of analysis is a loosely articulated idea that states may...

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...

French Abstract: Le thème central du livre est celui de la compétition fiscale qui oppose les États à l'échelle internationale. Abordant cet enjeu, Dietsch présente une solution interdisciplinaire au problème qui touche tant l'économie que le droit et la philosophie. Notre recension...

This chapter for a forthcoming text on investment promotion explains the concept of “luring with tax”. It first lays out in broad strokes how nation states compete with each other for direct and portfolio investment using their tax systems. It then analyzes whether using the tax system as an...

This document contains four installments of "The Big Picture," a column published in Tax Analysts, International Tax Notes, Volumes 66-68 (2012). The first installment, "Putting Arbitration on the MAP: Thoughts on the New U.N. Model Tax Convention," discusses the addition of mandatory...