The Tax Cuts and Jobs Act (TCJA) includes several provisions that may be viewed as potential violations of US tax treaties. However, most of those potential violations, such as new IRC section 951A and to a large extent new IRC section 59A, are covered by the Savings Clause (US model article...

This essay argues that the current COVID-19 crisis is the perfect time to make revenue-raising reforms to state corporate income taxes — reforms that would have been desirable policy improvements even during an economic upturn, but that are even more clearly good policy moves in light of the...

Tax Cuts and Jobs Act (“TCJA”) signed into law by President Trump on 22 December 2017 contains multiple provisions that significantly impact Europe and the way European corporations are being taxed by the US. The US corporate tax rate is set to be 21% (reduced from 35%). Most importantly,...

If one listens to what Democratic and Republican candidates for president are saying on the campaign trail, the chances for tax reform in 2017 and beyond appear to be minimal. To pass tax reform, a bipartisan approach is essential, because even if we have a Republican president and Republican...

This paper has suggested that as we consider tax reform in 2014 and thereafter, we should revert to some of the positive features of TRA 86, updated to reflect increasing globalization. Specifically:a. The top individual rate, the KG rate and the dividend rate should be set at 28%;b. The...

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...

This paper aims to suggest two proposals for solving the current problems of the U.S. international tax regime that can be implemented on a bipartisan basis. To do so, the first section below will provide some context. The next section will survey recent reform proposals by both U.S....