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...

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 document contains four installments of "The Big Picture," a column published in Tax Analysts, International Tax Notes, Volumes 66-68 (2012). The first installment, "Putting Arbitration on the MAP: Thoughts on the New U.N. Model Tax Convention," discusses the addition of mandatory...

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,...

The extent of the information subjected to automatic exchange under the scope of cross border tax administrative cooperation is increasing day by day. Nowadays, financial accounts, non-financial categories (such as changes of domicile, immovable property acquisitions and transfers, value added...

Conventional wisdom explains tax competition as an external constraint on lawmaking that can only be curbed through multinational cooperative efforts to eliminate beggar-thy-neighbor tax policies. But the international tax reform plan recently introduced by Senator Baucus squarely confronts this...

Tax reform is a constant process in most nations as governments continuously revisit their tax regimes in response to economic, social, and political forces. Domestic legislative processes are the most obvious source of change in the tax system in any independent nation, but international...

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...

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...