The United States is currently trying to manage a fast-moving public health crisis due to the coronavirus outbreak (COVID-19). The economic and financial ramifications of the outbreak are serious. This Working Paper discusses these ramifications and identifies three interrelated but potentially...

Since the turn of the current century, leading transnational organizations and academic scholarship have identified tax competition among countries as one of the scourges of the international tax regime. Both the EU and the OECD have warned that tax competition erodes the tax bases of Member...

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be...

A controversial new financing phenomenon has recently emerged. New “income share agreements” (“ISAs”) enable an individual to raise funds by pledging a percentage of her future earnings to investors for a certain number of years. These contracts, which have been offered by entities such...

This study was drafted as the EU topical report for IFA's general report on the topic reconstructing the treaty network and deals with the intersection of three areas: i) European Union law; ii) the OECD's Base Erosion and Profit Shifting project (BEPS) and its implementation, and; iii) member...

Congress is likely to consider domestic climate change legislation during 2009, with a cap-and-trade system continuing to draw support from the Obama Administration and many leaders in Congress. Yet cap-and-trade regulations would take years for EPA to develop and implement, the desired price...

The Internal Revenue Code is riddled with features that allow U.S. taxpayers to reduce their federal tax liability by operating through tax haven companies. Some of these provisions are historic anomalies. Others are better understood as inadvertent loopholes than considered legislative grace....

Analysis of the United States and Greenland Agreement to Improve International Tax Compliance and Implement FATCA, goes through the FATCA agreement from a legal lens. As the world’s largest island, and one that is rapidly being looked to for tourism and mining, the importance of tax...

With the growth of electronic commerce tax authorities were faced with the challenge of applying traditional tax principles, which have been developed in times where business comprised the delivery of physical goods and services were provided in face-to-face transactions, to cross-border...

Global climate change, largely the result of carbon emissions brought about by a global economy addicted to fossil fuel and committed to economic expansion, threatens the very viability of the economy that causes it. The relatively cheap price of fossil fuels does not account for the costs to...