International tax planning strategies, by their very nature, increase firms’ free cash flows, which could improve companies’ creditworthiness. However, these strategies also bring information and agency problems, which may reduce their creditworthiness. To understand which of these effects...

The goals of transfer pricing are to assign a monetary value to a transfer and to minimize the taxes paid by a company as whole. However, because a single company can now have operations literally around the world, transfer pricing has become a very complicated, costly, and lucrative business...

International restructuring is frequently a necessary element in global tax planning. Restructuring based on “arm's length” principles often involves transferring and paying for goodwill. Goodwill may be hard to identify and ephemeral, and presents difficult problem for accountants and tax...

This essay makes a proposal that might be controversial among tax scholars even if it is non-controversial to those with a particular interest in international law: that international social and institutional structures shape, and are shaped by, historical and contemporary domestic policy...

Tax scholarship typically presumes the state’s power to tax and therefore rarely concerns itself with analyzing which relationships between a government and a potential taxpayer normatively justify taxation, and which do not. This paper presents the case for undertaking such an analysis as a...

This article reviews Avi-Yonah, Sartori, and Marian's Global Perspectives on Income Taxation Law (Oxford, 2011). It outlines the book's key features and strengths in the quest for understanding the effect of globalization on taxation. In this process, the article also looks into available data...

Assume a hypothetical but very plausible scenario in which you had invested substantial fortune and efforts in a cross-border transaction. You entered this transaction after a thorough field study and you even consulted some tax experts in order to estimate your potential tax burden. The tax...

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...

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...