This position paper of the IBFD Academic Task Force (hereinafter IBFD Task Force) relates to the OECD's work on BEPS Action 1 and is devoted to withholding tax aspects. This position paper provides possible solutions to the challenges presented to the international tax regime by the digital...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

This article examines the role that international comparisons play in current corporate tax reform discourse in the United States. Citing the need to make the U.S. corporate tax system more competitive, comparisons are frequently used to assess other jurisdictions' tax-competitiveness, and many...

In light of the UK Coalition Government's announced intention to reform APD (Air Passenger Duty), this article examines the design flaws making APD an inadequate environmental tax. By identifying the misconceived consequences and environmental inefficiencies of this blunt instrument, the need...

This document is the final report of the Consultative Committee on Full Imputation and International Tax Reform. This final report outlines the Committee's recommendations on the outstanding issues relating to both sets of reforms. It explains the policy behind draft legislation produced by the...

Justice Edmonds' judicial output was large, but it did not prevent him from presenting several extra-judicial speeches and papers every year. These represent an impressive body of work: both scholarly and practical. In these writings, Edmonds J analyses the Australian tax system and advocates...

The article aims to appreciate the U.S. tax reforms, especially in topics related to international taxation, emphasizing the analysis of their potential incompatibility with the World Trade Organization (WTO) law. It will be discussed in the U.S. international tax environment before the U.S. tax...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...

The main purpose of this book is to promote the dissemination of the basic notions of taxation from a policy, legal and administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The book sets out current principles of taxation...

In the Dec. 10, 2007, issue of Tax Notes, Contributing Editor Lee Sheppard stated that the treaty benefits provision in the Tax Reduction and Reform Act of 2007 (H.R.3970, sec. 3204) was essentially the same as the Doggett provision in sec. 12001 of the farm bill, H.R.2419. I analyze the...