The near adoption of Worldwide Combined Reporting (WWCR) in Minnesota has led to a blizzard of critical claims about WWCR from corporate tax lobbyists, the Tax Foundation, and the editorial board of the Wall Street Journal. These various groups have made a number of policy arguments that do not...

This paper performs a forensic analysis of Microsoft Corporation’s transfer pricing cost sharing arrangement based on forensic economic analysis of public and information, including Microsoft’s SEC and foreign country regulatory filings, documents disclosed during a recent federal court...

Value added taxes are destination based, i.e., tax is imposed on imports and exports are zero rated (so that the exporter can receive a refund on VAT collected in previous stages of production). Income taxes, on the other hand, are typically origin based, i.e., imports are deductible and exports...

Congress is likely to consider domestic climate change legislation during 2009, with a cap-and-trade system continuing to draw support from the Obama Administration and many leaders in Congress. Yet cap-and-trade regulations would take years for EPA to develop and implement, the desired price...

Finding ways to help bridge the North/South divide in terms of life expectancy, health, and living conditions may be the most important task facing humanity at the beginning of the 21st century. The Millennium Development Goals adopted by the UN are a beginning step toward that goal, and require...

The current debate on whether the US tax base should be income or consumption has been waged in terms of the traditional criteria for evaluating tax policy - efficiency, equity and administrability. Proponents of the consumption tax have argued that it is superior to the income tax on all three...

This paper addresses the relationship between tax and trade law, as embodied in the network of bilateral tax treaties and the multilateral agreements underlying the WTO. The paper argues that: (1) There is considerable overlap in the goals to be achieved by tax and trade agreements, and full...