The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be...

Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational...

These slides were prepared for lectures I gave at law schools in Shanghai and in Israel the week of November 13, while the Tax Cuts & Jobs Act of 2017 (H.R.1) was under active consideration in the U.S. House of Representatives and the Senate version of the Tax Cuts and Jobs Act was being...

Debate about U.S. international tax policy often emphasizes norms, such as capital export neutrality (CEN) and capital import neutrality (CIN), that relate to worldwide welfare rather than U.S. national welfare. While this focus may seem paradoxical, or at least surprisingly altruistic in a...

This paper investigates the effects of multinational corporations on labor standards. We argue that the previous literature has failed to distinguish the different motives that encourage firms to become multinational. Therefore, we build a stylized model of segmented labor markets with...