Today, more than ever the battle against tax evasion is taking a center stage in the global political agenda. Hence, leading countries are intensifying their efforts and adding tools to assist in the pursuit of information concerning the international business activities of their taxpayers. The...

There is a wide bipartisan consensus that the US international tax regime is broken. We have the highest corporate tax in the OECD, which at 35% imposes a real burden on corporations earning mostly US source income. At the same time, US based multinationals pay very low effective tax rates on...

In "Understanding the AMT, and Its Unadopted Sibling, the AMxT." J. Legal Analysis (Advance Access: October 8, 2014), Jim Hines and Kyle Logue propose an interesting new theory about why the US has an Alternative Minimum Tax (AMT). The function of the AMT, they propose, is to enable Congress to...

This article will survey the great consumption vs. income tax debate from a historical perspective. The focus here is not on which tax base is better, but rather on how this debate evolved over time inside and outside legal academia. As we shall see, there was one point in which the consumption...

The OECD's Base Erosion and Profit Shifting (BEPS) project promises to bring about the most fundamental changes in the international tax regime since its inception in the 1920s. The fundamental idea behind the various BEPS projects is that the OECD has fully embraced the idea that double...

This paper has suggested that as we consider tax reform in 2014 and thereafter, we should revert to some of the positive features of TRA 86, updated to reflect increasing globalization. Specifically:a. The top individual rate, the KG rate and the dividend rate should be set at 28%;b. The...

On September 22, 2014, the Treasury issued Notice 2014-52 (the “Notice”). The Notice was intended to fulfill President Obama's pledge to use executive actions to the extent possible to block the new wave of corporate inversions. To what extent can the Notice succeed?This article will argue...

The current tax treaty network was developed in the 1920s and 1930s in order to prevent double residence/source taxation. This kind of double taxation rarely exists any more because most countries have adopted either an exemption system or a foreign tax credit regime in their domestic...

The debate about whether to abolish deferral or to adopt territoriality has been going on ever since the Kennedy Administration first proposed ending deferral in 1961. The problem is that neither side has factual support for their argument about whether the U.S. tax system, including Subpart F,...

Imagine that a single person had been responsible for all US tax reforms enacted from 1969 to 2010. Such was the position of Seven-Olof Lodin, the former President of the International Fiscal Association. For over 40 years, Professor Lodin was the most influential voice in Swedish tax policy....