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...

The United States approach to taxing foreign-source income is a hybrid worldwide system in form. However, because of deferral of U.S. tax on foreign-source active business income, liberal cross crediting opportunities and other defects, the U.S. system can actually produce a...

Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International's corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages,...

This testimony makes three main points. First, inheritances tend to exacerbate existing economic disparities and may be the most important barrier to intergenerational economic mobility. These tendencies are most pronounced at the top of the income distribution. While inherited income is...

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 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...

The October 2020 Pillar One proposal by the OECD/Inclusive Framework (IF) is designed to shift some portion of the global pre-tax profits of multinational enterprises (MNEs) in automated digital services (ADS) and consumer-facing businesses (CFB) to Market jurisdictions where ADS and CFB...

Corporate income tax law in OECD countries requires multinational enterprises (MNEs) to set their transfer prices according to the arm's length standard. In 1990, the US government introduced a transfer pricing penalty for cases where MNEs deviated substantially from this standard. Most OECD...