Imagine that a single person had been responsible for all US tax reforms enacted from 1969 to 2010. Such was the position of Seven-Olof Lodin, the former President of the International Fiscal Association. For over 40 years, Professor Lodin was the most influential voice in Swedish tax policy....

The Supreme Court's decision to grant certiorari in the PPL case offers it a unique opportunity to change the law regarding foreign tax credits that has significantly impeded the ability of other countries to engage in meaningful tax reform. In 1938, the Court said in dicta that to qualify for...

The COVID-19 Pandemic already feels like a historical turning point akin to Word Wars I and II and the Great Depression. It may signal the end of the second period of globalization (1980-2020) and a change in the relative positions of the US and China. It could also lead in the US to significant...

The 2017 tax legislation brought sweeping changes to the rules for taxing individuals and business, the deductibility of state and local taxes, and the international tax regime. The complex legislation was drafted and passed through a rushed and secretive process intended to limit public comment...

Today, more than ever the battle against tax evasion is taking a center stage in the global political agenda. Hence, leading countries are intensifying their efforts and adding tools to assist in the pursuit of information concerning the international business activities of their taxpayers. The...

The Tax Cuts and Jobs Act of 2017 (TRA17) represents the most comprehensive reform of US international tax rules since 1962. An important question in evaluating TRA17 is how US trading partners will respond to its provisions. In general, US trading partners may take steps to negate the...