Controlled foreign corporation rules are a fundamental piece of the international tax regime. They preserve national tax bases from erosion and profit shifting, counteract tax deferral and implement capital export neutrality policies. However, the application of these rules should be coordinated...

This article springs from two concurrent phenomena. First, U.S. federal deficit spending projections indicate that any feasible deficit reduction plan will require substantial additional revenue. Second, the U.S. system for taxing foreign-source income is so badly flawed that if the United...

Tax treaties are often viewed as a mechanism for eliminating tax competition, however this approach ignores the need for bargaining over the treaty's terms. This paper focuses on how bargaining can affect the withholding taxes set under the treaty. In a simple framework, we develop hypotheses...

The main purpose of International Taxation Core Concepts is to show managers, lawyers, accountants and others how tax laws affect global management decision-making. Part I of the book is a case study (or ‘tax novella') called La Brienza Winery: Tax Trouble in Wine Country that illustrates how...

The concept of treaty abuse, although being of great significance to the operation of international tax treaties, is by no means peculiar to this particular branch of law. A treaty abuse doctrine exists in general international law since long. As this paper argues, current work within the OECD,...