Debate about U.S. international tax policy often emphasizes norms, such as capital export neutrality (CEN) and capital … paradoxical, or at least surprisingly altruistic in a world full of self-interested players, it potentially makes sense from a … sufficiently reciprocal. This suggests that criticisms of U.S. international tax policy debate for focusing too much on worldwide …

The terms “enterprise,” “business” and “business profits” are ubiquitous in U.S. and international tax law yet they are …. Part I deals with the meaning of these concepts under domestic non-tax legislation, with a particular focus on private law …, commercial law, company law and bankruptcy law. Part II describes the concepts under domestic tax law with reference to relevant …

in U.S. international tax rules can be explored. The question it poses is straightforward: Assume that our task is to … through a U.S.-parented or foreign-parented multinational corporate group (“MNE”). What U.S. rate of tax will apply to income … currently and, in the case of the new GILTI tax, the mix of assets deployed in offshore operations. Nevertheless, we can …

This paper — prepared for a symposium held at Brooklyn Law School on October 23, 2015 on Reconsidering the Tax Treaty … — addresses the treaty compatibility aspect of proposals for reforming the U.S. international tax system. Finding that a reform … reading of Article 23 of the U.S. model income tax treaty as requiring a credit system, the paper argues that any system that …

.S.-Canada tax treaty. This book provides a fresh look at "PE in the U.S." using the U.S.-Canada treaty as a case study. It also … was fairly representative of late-twentieth-century U.S. tax treaties. The protocol signed on September 21 made it cutting …

itself in the perilous situation of needing to raise tax revenue while retaining the support of moderate Democrats. President … corporate tax rate from 21 percent to 28 percent. These changes are unlikely to become law. Together, they simply do not have … Administration’s conundrum by proposing a worldwide no deferral system with a corporate tax rate in the mid to high teens. In fact …

This article examines some of the background to the 1954 Japan-United States Income Tax Treaty from a historical … perspective.Japanese domestic law developed the “source” of income concept and implemented a foreign tax credit system during the … these domestic law principles. Japanese law and US law, through the medium of tax treaties, affected each other. The treaty …

This Article considers the effects of EC law on U.S. tax treaty policy. The discussion is framed by the controversy … over the legality of tax treaty limitation on benefits clauses (LOBs) in the wake of recent ECJ decisions, and it argues … that U.S. tax treaty policy is on a collision course with the tax jurisprudence of the ECJ …