The copiousness of tax treaties is often presented as living proof not only of their success but also of their desirability. However, in focusing on alleviating double taxation by allocating tax revenues, the treaties project is a missed opportunity. This article explains that an international...

The global competition for residents and investments inevitably transforms the very foundation of for countries' tax policy. It alters the way we (should) think of the classic normative goals of income tax policy. Efficiency, redistribution and even the concepts of community, national identity...

Globalization and tax competition challenge residence base taxation of corporations, by pushing states to offer competitive “deals” in order to attract corporate-residents. This paper will describe this process and ask whether states could regain their power to tax corporations on a...

This article examines the appropriate tax treatment of communities through the unique example of the Israeli kibbutz, a community that is traditionally governed by the maxim "from each according to his ability, to each according to his needs." The case of the kibbutz highlights the tension...

This paper describes the multilateral efforts regarding four key concerns of the international community: prevention of double taxation, fighting "harmful tax competition," sharing of information, and the "gaps and frictions" between the tax systems of various countries noted by the recent BEPS...

Commodification has become the central parameter in delineating the contours of the market and in the division of labor between the market and the state. The commodification critique has become a 'buzz word' against the market and thus in support of State intervention. In what has been termed...

Tax sovereignty under globalization is at risk of unraveling. This is not only–as is often argued—because international organizations or other states exert external power on sovereign states. It is also the very process of fragmentation of state sovereignty that undermines its own...

The competitive and fragmented reality of tax under conditions of globalization is transforming tax sovereignty. It undermines the coercive power of the state to tax and threatens domestic justice. Given the state’s fading coercive power in taxation we can no longer assume that ideals of...

Policymakers and scholars troubled by the race to the bottom created by tax competition espouse a cooperative multilateral solution that will compel universal cooperation. This chapter suggests that cooperation should be treated with caution, as – despite its positive reputation –...