This essay makes a proposal that might be controversial among tax scholars even if it is non-controversial to those … shaped by, historical and contemporary domestic policy decisions. As a result, tax law scholars must seek a broad framework … for understanding the rapid changes that are taking place in tax policy and politics. Our aim in this essay is to further …

This article, which is based on the inaugral address given at the IBFD Tax Lecture Series in Beijing, China, examines … the basic foundations and nature of income tax law before going on to offer a unifying theory of taxation law. Income tax … law is notoriously complex for a range of reasons. One is that tax law must address a huge and never-ending range of …

“Ectopia” is a label given here to a feature of tax law that distinguishes it from most other forms of law. Income tax … law is dislocated from the facts to which it relates. This dislocation leaves a gap, or “ectopia” between tax laws and the … economic facts of the transactions or structures to which it relates. The ectopia of income tax law is pathological, serious …

This is the tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax … violations further expose the problems and injustices of the U.S. extraterritorial tax system and underscore the system … has neither a compelling nor a legitimate interest in continuing the U.S. extraterritorial tax system …

We present four important dimensions to international tax policy from a tax-systems perspective, stressing that non …-rate/base tax policies can have different cross-jurisdictional spillover effects than changes in tax rates. The dimensions are the … efforts in tax policy and tax administration, and information sharing about governments' tax practices. The paper discusses …

In his David R. Tillinghast Lecture given at NYU in 1998, H. David Rosenbloom presented the tax world with a critical … view as to the existence of an “international tax regime”. Has the world changed since? On the one hand there is a strong … move towards international tax coordination, including multilateral agreements and the creation of new institutions …

In this paper it is controversially suggested that international tax law is broader than the traditional view of most … multilateral counterparts) there is a special consensus international tax law (CITL) based on the institutions, instruments and … tax systems and whether they constrain domestic taxation choices? In other words, are there limitations on States …

In his David R. Tillinghast Lecture given at NYU in 1998, H. David Rosenbloom presented the tax world with a critical … view as to the existence of an "international tax regime". Has the world changed since then? On the one hand, there is a … strong move towards international tax coordination, including multilateral agreements and the creation of new institutions …

This article discusses the current state of tax treaty interpretation in New Zealand with particular reference to a … resident was entitled to a tax sparing credit under the New Zealand/Chinese double tax treaty. The Lin case was decided in the … by the Court of Appeal the approach to tax treaty interpretation is the most concerning and significant. Consequently …

its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global …