The issue of tax-motivated income shifting within multinational firms has attracted increasing global attention in recent years. It is of central importance to many current policy debates, including those related to recent initiatives by the OECD on base erosion and profit shifting (BEPS) and to...

Cross-border tax evasion has emerged in recent years as a central issue in tax enforcement. Traditionally, the legal regime governing cross-border tax enforcement was based on information exchange upon request. In 2010, the US Congress enacted the Foreign Account Tax Compliance Act (FATCA),...

This paper proposes and evaluates alternative methods for addressing the tax treatment of interest expenses in a multijurisdictional setting. The differential deductibility of debt entailed by various current tax law provisions leads to potential distortions in the patterns of asset ownership...