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 proposal is treaty compatible obviates the...

The last time someone wrote comprehensively about permanent establishment in the United States, the catchwords of the day were Mayaguez, Watergate, and Squeaky Fromme. At that time, there were only nine U.S. cases and thirteen revenue rulings addressing permanent establishment. Perhaps not...

This Article compares the ways in which the United States and the European Union limit the ability of state-level entities to subsidize their own residents, whether through direct subsidies or through tax expenditures. It uses four recent charitable giving cases decided by the European Court of...

U.S. Treasury officials and members of Congress from both parties have expressed concern that the European Commission's current state aid investigations are disproportionately targeting U.S.-based multinational enterprises. At the same time, a Treasury official recently suggested in...

This chapter describes some of the major regional GHG cap-and-trade initiatives in the United States, defines the problem of emissions leakage in the context of regional GHG regulation, identifies the various approaches employed by the regional GHG cap-and-trade regimes in the United States to...

In this paper the impact of the corporate tax systems of the 15 EU-member states on the investment and the financing decision of an US multinational corporation is analysed. The calculation of the resulting effective marginal tax rates (EMTR) closely follow the model of King and Fullerton. There...