Since the advent of state sovereignty with the Peace of Westphalia, powerful Western nations have determined and applied international law in a manner that advance their national interests. In short, the international legal process has been a mechanism of hegemony, and powerful Western nations...

In Part IV, Dean Marsan examines FATCA withholding liability for withholdable payments under Code Secs. 1471 and 1472, and provides a nine-point analysis - each of which must be answered affirmatively for the new 30-percent withholding tax to apply

Part IV examines FATCA withholding liability for withholdable payments under Code Secs. 1471 and 1472, and provides a nine-point analysis—each of which must be answered affirmatively for the new 30-percent withholding tax to apply

Schemes of residual profit allocation (RPA) tax multinationals by allocating their 'routine' profits to countries in which their activities take place and sharing their remaining 'residual' profit across countries on some formulaic basis. They have recently and rapidly come to prominence in...

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...

Cross-border tax disputes are usually channelled through the "mutual agreement procedure", an informal negotiation between the tax authorities of the states involved. Arbitration has been suggested as an alternative, and is starting to be instituted. Arbitration will probably be a good "stick"...

Under the North American Free Trade Agreement (NAFTA), Canada, the United States, and Mexico continue to maintain their own distinct tax regimes, jealously guarding their sovereign right to do so. At times, these different tax systems harm the economic welfare of the trade bloc by imposing...

I describe the mechanisms by which cryptocurrencies — a subcategory of virtual currencies — could replace tax havens as the weapon-of-choice for tax-evaders. I argue such outcome is reasonably expected in the foreseeable future due to the contemporary convergence of two processes. The first...

Activists around the world seek to expose a global system that fails to tax multinationals adequately and thus deprives governments of needed revenues, with profound effects for development in the world's poorest nations. These tax activists have sparked a global movement, with groups all over...