Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries....

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...

With increased technology and access to information, corporations have evolved in order to reflect the concept of corporate social responsibility (CSR) in their global business strategies. Some companies, such as Starbucks Corporation, have taken this concept a step further and chose to...

This paper will be focused on the evolution of the corporate tax world and how Corporate Social Responsibility (CSR) may affect the tax planning of multinational companies. An analysis of the history of reform to the United States tax system will be done starting with its inception in the early...

The BEPS project would, it was said, establish 'a fundamentally new set of standards designed to establish international coherence in corporate income taxation.' While many of the items in the Action Plan are better described as tinkering, item 2 was directed to 'international coherence in...

This outline, prepared for the 52nd Annual Great Plains Tax Institute in Omaha, Nebraska (December 4-5, 2014) covers significant developments in federal income taxation along with a few other interesting or noteworthy tax topics. It is not intended to provide exhaustive coverage, but it offers a...

These materials discuss as well as provide context to understand the significance of the most important judicial decisions and administrative rulings and regulations promulgated by the Service and Treasury during 2017. Amendments to the Code generally are not discussed except to the extent that...

Although the literature has extensively discussed the issue of corporation residence, it has paid little attention to the terms of reference of the debate. A typical argument will take the following form: the law should adopt Definition D as appropriate because it closely conforms to Principle...

The term “sharing economy” is flawed, but are the alternatives any better? This Essay evaluates the uses of competing narratives to describe the business model employed by firms like Uber, Lyft, TaskRabbit, and GrubHub. It argues that while the term “sharing economy” may be a misnomer,...

For nearly all advanced industrialized nation-states, taxation is the central source of public revenue. Indeed, taxation is the one policy area without which nearly all of the other functions and aspects of the modern state would not be possible. Thus, to continue the Bourdieuian metaphor of a...