During the course of the last 100 years, the wealthiest and most powerful nations on the planet have systematically gathered around in small groups of experts, scientific committees and working parties, under the auspices of the League of Nations and the OECD, to decide on the appropriate tax...

This document contains four installments of "The Big Picture," a column published in Tax Analysts, International Tax Notes, Volumes 66-68 (2012). The first installment, "Putting Arbitration on the MAP: Thoughts on the New U.N. Model Tax Convention," discusses the addition of mandatory...

This chapter for a forthcoming text on investment promotion explains the concept of “luring with tax”. It first lays out in broad strokes how nation states compete with each other for direct and portfolio investment using their tax systems. It then analyzes whether using the tax system as an...

Conventional wisdom explains tax competition as an external constraint on lawmaking that can only be curbed through multinational cooperative efforts to eliminate beggar-thy-neighbor tax policies. But the international tax reform plan recently introduced by Senator Baucus squarely confronts this...

Through decades of tax reform and cross-border collaboration, the world's wealthiest countries have adopted domestic tax policy norms that meet their mutually beneficial interests. But these norms have introduced rigorous change and increasingly rigid parameters for tax policy in the world's...

The extent of the information subjected to automatic exchange under the scope of cross border tax administrative cooperation is increasing day by day. Nowadays, financial accounts, non-financial categories (such as changes of domicile, immovable property acquisitions and transfers, value added...

The IRS recently announced that its mandatory registration regime for paid tax return preparers, struck down in the Loving decision, would henceforth be offered as a voluntary program. But the authors of this program appear to have forgotten that the US system is perfectly global in reach,...

French Abstract: Le thème central du livre est celui de la compétition fiscale qui oppose les États à l'échelle internationale. Abordant cet enjeu, Dietsch présente une solution interdisciplinaire au problème qui touche tant l'économie que le droit et la philosophie. Notre recension...

The United States enacted a tax reform in 2010 known as the Foreign Account Tax Compliance Act (FATCA), which will impose an extensive third-party monitoring and disclosure regime on financial institutions around the world in an effort to “smoke out” American tax cheats and expose their...

When Congress enacted the Foreign Account Tax Compliance Act in 2010, it made no mention of any internationally-agreed alternative to its enforcement, and Congress has made no authorization since then for the president to override FATCA's statutory provisions by international agreement. Yet due...