Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...

FATCA is a US domestic tax policy that requires Foreign Financial Institutions around the world to provide the IRS information regarding their US clients. Recognizing this extraterritorial characteristic and the troubles associated with it, the US Treasury Department developed the...

We present four important dimensions to international tax policy from a tax-systems perspective, stressing that non-rate/base tax policies can have different cross-jurisdictional spillover effects than changes in tax rates. The dimensions are the allocation of global income among taxing...

Modern developments raise significant questions about the future importance (or non-importance) of formal citizenship status. For example, while many have interpreted the European Union project, with its emphasis on the free movement of individuals, as portending the decreasing relevance of...

International tax avoidance by multinational corporations is now front-page news. In a time of public austerity, citizens and legislators around the world have focused on the erosion of the corporate income tax base. In response, in 2012 the G-20 — the gathering of the leaders of the world's...

A report on a conference organised jointly by the Institute of Policy Studies, Wellington, the Asian Pacific Tax and Investment Centre, Singapore, and the Australian Tax Research Foundation, Sydney. The purpose was to study judicial and legislative anti-avoidance measures and treaty policies in...

In both Australia and the U.S., the tax anti-avoidance law has evolved to include two common doctrinal components. One component requires evidence of taxpayers' tax avoidance purpose. The other component protects transactions clearly contemplated by the tax statute against charges of tax...

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 Article compares the ways in which the United States and the European Union limit the ability of state-level entities to subsidize their own residents, whether through direct subsidies or through tax expenditures. It uses four recent charitable giving cases decided by the European Court of...

This is the fifteenth in a series of sixteen papers about the U.S extraterritorial tax system.This article:- Cautions against any new U.S. tax system that would perpetuate the constitutional and human rights violations of the current system; - Explains how other countries are able to further the...