The principle of horizontal equity is usually accepted on intuitive grounds. Whereas the other major principles of tax theory - vertical equity and economic efficiency - have been the subject of vast literature, the theoretical underpinnings of horizontal equity are rarely if ever challenged....

Since the turn of the current century, leading transnational organizations and academic scholarship have identified tax competition among countries as one of the scourges of the international tax regime. Both the EU and the OECD have warned that tax competition erodes the tax bases of Member...

Although the literature has extensively discussed the issue of corporation residence, it has paid little attention to the terms of reference of the debate. A typical argument will take the following form: the law should adopt Definition D as appropriate because it closely conforms to Principle...

Probably the most uncontroversial thing that one can say about international taxation is that it is a mess. Sophisticated planning techniques, which seem beyond the power of taxing authorities to control, enable highly profitable multinational enterprises (MNEs) to pay little or no tax on their...

Tax avoidance attracts a great deal of attention from both academics and policymakers. To combat the phenomenon, Congress has enacted numerous statutory provisions that either deny beneficial treatment when one of the taxpayer’s principal purposes was tax avoidance or attempt to dissuade...