In this paper, we discuss the hypothetical impact of the Amount A regime on US corporate income tax revenue. The general outline of the two-pillar taxation system, which includes Amount A as a part of Pillar One, was agreed upon in October 2021 by the Inclusive Framework delegates who tackled...

This National Report was prepared for the 2014 Annual Congress of the European Association of Tax Law Professors, which took place in May 2014 at Koç University, Istanbul, Turkey. This National Report discusses administrative and legal mechanisms, especially the Foreign Account Tax Compliance...

This National Report was prepared for a conference titled Tax Secrecy and Tax Transparency – The Relevance of Confidentiality in Tax Law, which took place in July 2012 in Rust, Austria and was co-hosted by the Institute for Austrian and International Tax Law at the Vienna University of...

One of the most notable examples of U.S. tax exceptionalism is the taxation of U.S. citizens and legal permanent residents (LPRs) on their worldwide income, regardless of residence. The United States also imposes broad and increasingly onerous tax and financial reporting obligations on its...

The Protecting Americans from Tax Hikes (PATH) Act of 2015 was recently signed into law by the US President Obama, and one provision (section 126) in particular benefits venture capital, private equity, and other investors owning or planning to purchase a US corporation

This article discusses the task of identifying controlled transactions under review by the Commissioner of the Internal Revenue Service. In particular, it aims to alert courts as to the necessary role of contractual interpretation law in determining the true nature of such controlled transactions

This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

[This testimony was delivered on December 8, 2021, to the House Committee on Ways and Means, Subcommittee on Oversight, as part of a hearing on "The Pandora Papers and Hidden Wealth."]The US is the world’s leading investment destination for offshore wealth. Our laws enable foreigners—through...

Analysis of the United States and Greenland Agreement to Improve International Tax Compliance and Implement FATCA, goes through the FATCA agreement from a legal lens. As the world’s largest island, and one that is rapidly being looked to for tourism and mining, the importance of tax...