Few thoughtful men or women will deny, as we enter the last two decades of the twentieth century, that ours is truly an Age of Anxiety. Even in an America still uniquely stable and prosperous relative to much of the rest of the world, the general mood is no longer an optimistic one. For many of...

This article is based on a lecture delivered at the NYU School of Law in September 2012. It puts into question the viability of the prevailing model for the allocation of income within a multinational enterprise (MNE), the system of transfer pricing based on the arms-length principle. The author...

In the first century AD, a tax was imposed on Jews throughout the Roman Empire following their unsuccessful revolt in Judaea. This "Jewish tax" effectively appropriated a biblically mandated temple tribute, continuing the form of the ancient levy as a poll or head tax but with a substantially...

The author provides some brief and immediate reactions to the Department of Finance's consultation paper on treaty shopping. These concern certain tax policy issues: the quantification of revenue loss, which implies some normative assumptions; the relevance of the residence of the owner to...