Different in more ways than it is possible to easily enumerate, the formation of the United States and the European Union (EU) had a striking similarity of purpose: to increase citizens' welfare by uniting a collection of independent states, each with its own politics, culture, and economy. Of...

This contribution tries to anticipate the possible consequences of the eventual introduction of an EU GAAR in the so called Anti-BEPS Directive for GAARs that already exist in the Domestic Law of EU Member States

This paper reviews the published literature on the definition and measurement of the administrative and compliance costs of taxation, with special reference to VAT (including evasion and fraud) in the European Union. -- Taxation ; Subsidies ; Revenue

This paper reviews the published literature on the definition and measurement of the administrative and compliance costs of taxation, with special reference to VAT (including evasion and fraud) in the European Union

Water is an exhaustible natural resource. Access to clean, safe and affordable water must be managed nowadays not only to avoid any unnecessary use of water, but also allow for continuous supply of such an important factor of public well-being. In recent years, water-related activities acquired...

This article asks whether tax planning advice can ever be effectively regulated by the IRS. The article first explores whether tax advice differs in kind from other forms of legal advice. Secondly, it looks at the clear regulatory distinction between the treatment of return preparation advice...

The Louisiana Supreme Court addressed the issue of whether someone could form an out-of-state LLC for no other purpose than to avoid the sales tax imposed on the purchase of vehicles. Plaintiff Roger Thomas freely admitted that he incorporated Angel Rocks, LLC under the laws of the State of...

Profit shifting activities of multinational enterprises (MNEs) result in base erosion in high-tax countries. Tax-motivated profit shifting may distort real investments of MNEs and encourage economies to engage in tax competition. To address the loss of tax revenues in high-tax jurisdictions, the...

This is a letter to the editor of Tax Notes Federal that highlights some changes to subsections (d) and (e) of section 954. These are the definitional rules for what is foreign base company sales income and foreign base company services income.I see this as something that was likely drafted by a...