Valuation issues have long posed challenges for the U.S. federal tax system. This is not just because of questions about what technique will most accurately value particular types of property. A key problem for tax administration is that taxpayers have an incentive to claim erroneous,...

We investigate real investment, financial revenues and profits in formerly domestic firms once they enter a multinational entity (MNE) through an acquisition. We argue that following the acquisition, those targets are tax-optimized in a profit shifting context if they are acquired by MNEs with...

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...

This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping. DTTs cannot be considered a bilateral issue, but must be viewed as a network, since FDI can flow from home to host...

The taxation of private equity managers' share of funds' profits — the twenty percent “carried interest” — received much attention in academic literature and popular discourse. Much has been said and written about the fact that fund managers' profits are taxed at preferred rates. But...

Among the ways in which multinational enterprises (MNEs) can shift profits from one jurisdiction to another in order to minimize taxes, one of the most simple and widely-employed involves the payment of interest to related parties and third parties. For these reasons, it is not surprising that...

Partnerships are the fastest growing class of business entity in the United States and represent over one third of reported business income, but due to their legal complexity and opaque nature economists have not yet been able to identify where a sizeable portion of this income goes. In this...

Due to advances in technology like mobile applications and online platforms, millions of American workers now earn income through “gig” work, which allows them the flexibility to set their own hours and choose which jobs to take. To the surprise of many gig workers, the tax law considers...