If one listens to what Democratic and Republican candidates for president are saying on the campaign trail, the chances for tax reform in 2017 and beyond appear to be minimal. To pass tax reform, a bipartisan approach is essential, because even if we have a Republican president and Republican...

With the election of Donald Trump and the Republican Party's domination of Congress, House Speaker Paul Ryan's blueprint for fundamental tax reform requires more careful analysis. The Ryan blueprint combines reduced individual rates with a destination-based cash flow type business tax applicable...

With the election of Donald Trump and the Republican Party's domination of Congress, it is time to seriously consider House Speaker Paul Ryan's blueprint for fundamental tax reform. The Ryan blueprint combines reduced individual rates with a destination-based consumption or cash flow type...

With the election of Donald Trump and the Republican Party's domination of Congress, it is time to seriously consider President Trump's tax plan and House Speaker Paul Ryan's blueprint for fundamental tax reform. The Trump plan lacks detail, but includes unrealistically large and regressive tax...

This paper aims to suggest two proposals for solving the current problems of the U.S. international tax regime that can be implemented on a bipartisan basis. To do so, the first section below will provide some context. The next section will survey recent reform proposals by both U.S....

Since the market is less subject to tax competition pressures than the location of headquarters or production facilities, reducing the PE threshold makes it easier to prevent BEPS. This has recently led some jurisdictions to enact new taxes aimed specifically at structures that seek to exploit...

Following the financial crisis and ensuing austerity, politicians discovered the problem of tax avoidance. In response, the OECD and G20 launched the Base Erosion and Profit Shifting (BEPS) project in 2013, and this has in October, 2015 culminated with the release of a series of action steps...

On October 5, 2015, the OECD and G20 released the final BEPS package. It included the following new preamble to the OECD model tax treaty:(State A) and (State B)…Intending to conclude a Convention for the elimination of double taxation with respect to taxes on income and on capital without...