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...

To what degree developing countries gain from signing double tax treaties is being hotly debated. In this paper, we analyze the Austrian tax treaty policy. Combining legal and economic perspectives, we find that developing countries are likely to expect both positive and negative impacts from...

This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping. DTTs cannot be considered a bilateral issue, but must be viewed as a network, since FDI can flow from home to host...

This paper examines the microeconomic motivation of governments to provide tax incentives for foreign direct investment. Author applies the classical models of oligopoly to subsidy competition, endogenousing investment incentives, but leaving tax rates exogenous. According to the conventional...

Multinational enterprises make use of tax havens to avoid paying corporate income taxes and this costs hundreds billion USD in lost government revenue worldwide according to an increasing number of recent studies. None of those studies assigns these costs to industries. I aim to shed more light...

The US Section 301 trade actions against DSTs were strikingly effective in the short term. Section 301, however, is ill suited as a process for challenging taxes of other countries and lacks legitimacy. The sovereign power to tax is very broad and there is insufficient international agreement on...

Capital mobility has preoccupied scholars of international taxation for more than 30 years. According to prevailing narratives, when capital is highly mobile, countries compete to attract investment, creating a race to the bottom; capital mobility also enables multinational enterprises (MNEs) to...

This paper assesses the impact of corporate taxation on multinational activity. A numerically solvable general equilibrium model of trade and multinational firms is used to incorporate the following components of corporate taxation: parent and host country statutory corporate tax rates,...

Der Aufsatz diskutiert die Verbreitung steuergesetzlicher Maßnahmen, die multinationalen Firmen eine bevorzugte steuerliche Behandlung einräumen. Der Schwerpunkt liegt dabei auf der Analyse der Aufkommens- und Wohlfahrtswirkungen von international koordinierten Maßnahmen, diese Steuervorteile...

The Article explains why international trade and tax arrangements should advance global wealth redistribution in a world of enhanced economic integration. Despite the indisputable importance of global poverty and inequality, contemporary political philosophy stagnates over the controversy of...