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,...

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...

The main objective of this paper is to analyze the current developments of international exchange of information taking into account the legitimacy of these instruments vis-á-vis the taxpayer including the protection of taxpayer's rights. The taxpayer rights addressed in this article are the...

The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. This article provides a detailed analysis of the global...

This article considers multinational enterprises' capacity to deduct interest expenses in light of the implementation of Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project and the OECD's current work on transfer pricing of financial transactions. It concludes that there has been a...

The present paper deals with the question how to tax multinational corporate groups in order to reduce inequality. Since inequality is abstract, it is necessary to interpret it, which implies referring to ethical concepts and theories. Ethical concepts argue that companies should generally be...

Globalization and the increasing trend in reduction of trade barriers have propelled businesses to capture growing levels of activity across borders. The range of such activities has been equally dispersed between the pursuit of new markets for products and services, and in the quest for more...