While tax havens are known as custodians and intermediaries of assets, this is the first paper to document that havens affect the ownership of assets on a large scale. We investigate cross-border, tax-haven mergers and acquisitions (M&A) using hand-collected data on tax residence laws and a...

In their article (NTJ 2021, 32-46), Scherer/Schmiel (1) postulate the introduction of a taxation of corporate groups on the basis of ethical responsibility according to a political-cultural market theory. The background to this is that corporate groups might apply tax avoidance or pay too little...

Hong Kong recently implemented the necessary changes to the domestic legislative to enable it to adopt the expanded exchange of information provisions based on the 2004 Organization for Economic Co-operation and Development (OECD) model convention for bilateral tax agreements. These amendments...

This paper analyzes the effect on firm behavior and national tax revenues of a policy of allowing multinational firms to choose whether to be taxed under separate accounting rules (transfer prices) or an apportionment formula. Either method can be preferred by low-cost firms and by high-cost...

This paper analyzes the effect on firm behavior and national tax revenues of a policy of allowing multinational firms to choose whether to be taxed under separate accounting rules (transfer prices) or an apportionment formula. Either method can be preferred by low-cost firms and by high-cost...

This Note proposes a solution to what has been one of the most vexing problems in state corporate taxation and in multijurisdictional taxation generally: the delineation of the scope of the entity that an individual jurisdiction is entitled to tax. Starting from the observation that the federal...

From 2009 to 2010, 98 percent of Google's and 99 percent of Oracle's subsidiaries disappeared from the Exhibit 21s filed with their SEC Form 10Ks. However, a March 2012 search of available public company registries revealed that at least 65 percent of the missing subsidiaries remained active as...

The main focus of this paper is on the international transfer pricing issues encountered by multinational enterprises (MNE) and the countries they do business in. This paper explores how the conflicting interests of MNEs and the countries they do business in affects each party's bottom line, tax...

This Article documents a process in which a national tax administration in one jurisdiction, is consciously and systematically assisting taxpayers to avoid taxes in other jurisdictions. The aiding tax administration collects a small amount tax from the aided taxpayers. Such tax is functionally...

Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts.The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but...