The existing double taxation agreement between the United Kingdom of Great Britain and Northern Ireland and the Polish People's Republic (signed back in 1976 amidst a political and economic détente promoted by the relatively liberal and progressive – on a COMECON scale – communist...

We construct a perfectly competitive general equilibrium model of two large and symmetric countries producing tradable commodities and a public consumption good. Destination or origin-based taxes are levied on the consumption of the tradable goods. In both countries, an institutional minimum...

During the course of the last 100 years, the wealthiest and most powerful nations on the planet have systematically gathered around in small groups of experts, scientific committees and working parties, under the auspices of the League of Nations and the OECD, to decide on the appropriate tax...

The IRS recently announced that its mandatory registration regime for paid tax return preparers, struck down in the Loving decision, would henceforth be offered as a voluntary program. But the authors of this program appear to have forgotten that the US system is perfectly global in reach,...

According to the Globalization Paradox, globalization limits the freedom of choice for national governments. Capital mobility in particular induces tax competition, thus putting downward pressure on capital taxes. However, while capital mobility introduces the inefficiency of tax competition, it...

French Abstract: Le thème central du livre est celui de la compétition fiscale qui oppose les États à l'échelle internationale. Abordant cet enjeu, Dietsch présente une solution interdisciplinaire au problème qui touche tant l'économie que le droit et la philosophie. Notre recension...

This chapter for a forthcoming text on investment promotion explains the concept of “luring with tax”. It first lays out in broad strokes how nation states compete with each other for direct and portfolio investment using their tax systems. It then analyzes whether using the tax system as an...

Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore...

Discourse on the merits and pitfalls of multilateral cooperation for advancing justice in international tax law have recently re-emerged in the literature. Some tax scholars, even while criticizing global projects like the OECD/G20 initiatives on base erosion, profit shifting and the tax...

This comment letter addresses Senate Finance Committee Chair Ron Wyden’s International Tax Reform Framework Discussion Draft released August 25, 2021 (with Senators Brown and Warner) (the WBW Draft). The comment discusses why U.S. multinationals have competitive advantages compared to...