This paper was submitted to the Department of Finance, Canada during the public consultation regarding proposals to eliminate some tax planning advantages for private corporations. It supports the direction of introducing more fairness in the tax system by preventing income-shifting (such as...

This Article analyzes the incorporation decisions of relatively new, U.S.-based private business enterprises with global ambitions. Such startup firms generally organize as U.S. corporations. This Article theorizes this dominant structure and its exceptions, drawing from prior literature and...