Michael J. Graetz delivered the following remarks at the Tax Policy Center's "A Corporate Tax for the 21st Century" conference on July 14 in Washington. These remarks are substantially taken from his April 2015 Ross Parsons Lecture at the University of Sydney Law School

Debate about U.S. international tax policy often emphasizes norms, such as capital export neutrality (CEN) and capital import neutrality (CIN), that relate to worldwide welfare rather than U.S. national welfare. While this focus may seem paradoxical, or at least surprisingly altruistic in a...

This Article considers the effects of EC law on U.S. tax treaty policy. The discussion is framed by the controversy over the legality of tax treaty limitation on benefits clauses (LOBs) in the wake of recent ECJ decisions, and it argues that U.S. tax treaty policy is on a collision course with...

The focus of this research is the analysis of Brazil’s international tax policy, understood as the group of justifications and goals of the Country in the drafting of its domestic tax legislation, levied on cross­border transactions, and in the negotiation of international tax treaties. This...

On January 1, 1994, Canada, the United States and Mexico formed the North American Free Trade Agreement (NAFTA) to promote their economic interests by lowering barriers to international trade and investment. A concern exists that national tax differences harm or inhibit cross-border investment...

A new international tax system will emerge in accordance with the global tax deal proposed by the OECD/G20 Inclusive Framework agreed by 137 countries. This will affect investment decisions of multinational enterprises in the future. The introduction of Pillar 1 may reduce the incentives for...

Professor Joseph Sneed a generation ago developed seven macro-criteria for evaluating income tax changes. This paper asks whether those criteria are useful in the general field of international income tax. I conclude that Adequacy, Practicality, Equity, and Free Market Compatibility are...