In their famous Mirrlees review (2011) on reforming the tax system for the 21st century, the authors put forward the introduction of an allowance for corporate equity regime. In recent years, several countries introduced an ACE regime. The main feature of an ACE regime is that it removes tax...

This paper discusses the issue of profit shifting and “aggressive” tax planning by multinational firms. The paper makes two contributions. First, it provides some background information to the debate by giving a brief overview of existing empirical studies on profit shifting and by...

This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

This paper discusses the issue of profit shifting and ‘aggressive’ tax planning by multinational firms. The paper makes two contributions. Firstly, we provide some background information to the debate by giving a brief overview over existing empirical studies on profit shifting and by...

The German corporate tax reform of 2008 has brought about important cuts in corporate tax rates, which were at the same time accompanied by significant changes in the determination of the tax base for both major German corporate taxes - corporate income tax and trade tax. The reform followed the...

The German corporate tax reform of 2008 has brought about important cuts in corporate tax rates, which were at the same time accompanied by significant changes in the determination of the tax base for both major German corporate taxes - corporate income tax and trade tax. The reform followed the...

Future increases to the top income tax rates for individuals and reductions to the corporate tax rate will invite the widespread use of C corporations as tax shelter vehicles, an old problem that has never been addressed successfully. The changes could even resurrect the need for the...

Following two decades of discussion, the border adjustment tax briefly emerged as part of proposed U.S. corporate tax reform in early 2017. While heavily debated, little empirical evidence exists regarding the border adjustment tax. We take advantage of the period during which the border...

This essay, scheduled to appear in the 2014 symposium issue of the Chapman Law Review, proposes enactment of a deduction to individuals for distributions received on stock in regular, or "C," corporations when the distributions are reinvested prior to the return date for the year of...

Traditional economic theory holds that a business cash-flow tax is superior to a business income tax because it is more efficient and progressive. But much of the literature espousing this view does not explicitly specify the full range of assumptions underlying these claims, let alone explore...