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...