This paper focuses on commenting on two separate aspects: (i) whether the current international tax environment that is leading us to some sort of “Imperial Taxation”, where taxpayers' rights are being eclipsed by State's revenue needs; and (ii) whether the BEPS Project might actually foster...

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...

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...

Canadian National Report prepared for the Vienna University of Economics and Business, Conference on tax secrecy and transparency, Rust, Austria, July, 2012. The aim of the project is to assess how different countries regard the treatment of tax information and tax secrecy. Topics include the...