This Article discusses the emergence of an international tax “war” and provides an overview of global digital taxation reform efforts. Governments have been unable to attain consensus surrounding how to tax cross-border digital transactions. As a result, dozens of governments are now...

Innovations in finance and information technology have radically reduced transaction costs, thereby stimulating the globalization of goods, services and capital. Capital mobility, the growth of multinational corporations, high frequency trading, complex financial instruments, and global equity...

The question of why and how to tax the digitalized economy has been at the top of the international tax policy debate since the inception of the BEPS Action Plan in 2013. Over the years, a number of approaches have been discussed, including far-reaching proposals to fully or partially...

Much work has been done by international organizations, tax scholars around the world and business experts on the future shape of the taxation of the digitalized economy. Starting from the assumption that any “ring-fencing” of the digitalized economy should be avoided, it is far from easy to...

We compile data spanning the period 1900–2014 and up to 30 countries to study long-run patterns in the tax elasticity of top incomes. Our results show that top tax elasticities vary tremendously over time; they were medium-to-low before 1950, virtually zero during the postwar era up to 1980 and...

The existing double taxation agreement between the United Kingdom of Great Britain and Northern Ireland and the Polish People's Republic (signed back in 1976 amidst a political and economic détente promoted by the relatively liberal and progressive – on a COMECON scale – communist...

Among government agencies, the IRS likely has the surest legal claim to the most information about the most Americans:their hobbies, religious affiliations, reading activities, travel, and medical information are all potentially tax relevant. Privacy scholars have studied the arrival of Big...

One of the aims of the BEPS Action Plan is to reduce existing leeway for multinational enterprises to shift profits by exploiting transfer pricing rules. Profit allocation is meant to be aligned with “real activity” and “value creation.” This article is devoted to the question of whether...

The paper highlights the interaction between the underground economy and corruption, focusing on the regional dimensions of the problem in south-eastern Europe. It discusses the theoretical approach to underground economic activities and focuses on the determinants of the Greek economy, the tax...

This study shows that domestic mergers and acquisitions (M&A) were inhibited by the U.S.'s worldwide tax policy on foreign-earned income. Double Irish structures, a complex web of subsidiaries that reduce foreign tax rates and therefore increase potential repatriation tax rates, are associated...