This paper sets forth a simple, but potentially infinitely expandable, model through which the consequences of changes in U.S. international tax rules can be explored. The question it poses is straightforward: Assume that our task is to aggregate funds from taxable U.S. or foreign individual...

This paper — prepared for a symposium held at Brooklyn Law School on October 23, 2015 on Reconsidering the Tax Treaty — addresses the treaty compatibility aspect of proposals for reforming the U.S. international tax system. Finding that a reform proposal is treaty compatible obviates the...

It is now the middle of 2015, and the broad outlines of the new BEPS principles are becoming clear. This paper examines these new principles, as laid out by the BEPS project, and analyzes their likely impact on tax revenues and jobs. We find that unless Congress and the Obama Administration act...

The increasing use of derivatives to manage financial risks raises significant challenges for legislators and tax administrators in forging a coherent U.S. tax regime. Through the creative use of derivatives, taxpayers can transform a highly taxed return into an economically equivalent but lower...

Introduction -- Beneficial Ownership : From Conscience to Liberalism and Law -- Beneficial Ownership in Tax Law -- From Domestic Tax Law to Tax Treaties : How Beneficial Ownership Jumped -- from US and UK Tax Treaty Policy into the Worldwide Tax Treaty Network -- Changing Skin in the OECD Model...

The terms “enterprise,” “business” and “business profits” are ubiquitous in U.S. and international tax law yet they are often ill-defined and under-theorized, especially in their interaction with other regulatory areas. This U.S. Report, commissioned for a comparative volume on the...