By taking the Great Wall of China as an analogy for China's treaty policy, the author considers key aspects of China's treaty network and its implications, and whether or not this constitutes a “Great Fiscal Wall of China.”Cited with the permission of IBFD

The debate rages on about how to tax private equity fund managers and hedge fund managers who, as part of their compensation, receive rights to share in fund profits (“carried interests”). Commentators have paid relatively little attention, however, to the impact that proposals to change the...

U.S.-based multinational corporations are calling for a tax holiday that would allow them to repatriate their foreign earnings at little tax cost. With over $1 trillion in earnings trapped offshore and untaxed by the U.S., these corporations characterize the proposed repatriation holiday as a...

The recent policy literature on fiscal federalism in China has concentrated on the large “vertical fiscal gap” resulting in inadequate local provision of public goods and services. Thus there is an evident interest in giving local governments more taxing powers. After a brief historical...

Almost fifty years ago in 1965, on the steps of the State Capital in Montgomery, Alabama, Dr. Martin Luther King, Jr., asked a crowd of twenty-five thousand "How long will prejudice blind the visions of men, darken their understanding, and drive bright-eyed wisdom from her sacred throne?" The...

The Supreme Court's decision to grant certiorari in the PPL case offers it a unique opportunity to change the law regarding foreign tax credits that has significantly impeded the ability of other countries to engage in meaningful tax reform. In 1938, the Court said in dicta that to qualify for...

On January 24, 1963, John F. Kennedy sent a message to Congress proposing tax reduction and tax reform. On the 50th anniversary of this event, this article reviews the political hurdles to its enactment, which were much more severe than generally realized today

Why do the promises of tax bills seemingly fade so quickly and why do revenue-raising provisions often fall short? That question has no single answer. However, part of the revenue shortfall may be attributable to a broad class of tax provisions that involve preemption by policymakers of...

Paper for the Rust Conference July 2013 ‘Trends and Players in Tax Policy' organized by Institute for Austrian and International Tax Law Vienna WU Global Tax Policy Center together with the Research Council of Norway. It discusses trends in tax policy in the Netherlands as from 2000 (personal...