Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

This paper examines the impact of Japan's 2009 adoption of a territorial tax regime using event study methods which leverage individual firm characteristics to identify underlying drivers of market reactions. Differences in Japanese firms' foreign and domestic effective tax rates yield an...

The Two-Pillar Solution agreed by 137 countries on 8 October 2021 has been hailed as “historic” and a “a once-in-a-generation accomplishment for economic diplomacy.” To a significant extent, this is due to the expected impact of Pillar 2 (essentially a global minimum tax) on tax...

This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

This study provides an interdisciplinary analysis of firm theory and international tax law, applied within a framework of hypothetical illustrations of prototypical multinational enterprises. The study finds that the construct and interpretation of different norms of international tax law...

The interaction of various methods of mitigating economic and international double taxation of corporate source income is studied within a standard neoclassical model of firm behavior. The main purpose is to determine to what extent methods effective in mitigating economic double taxation in a...