The ownership nationality of large US multinational companies plays an implicit but important role in the current debate over how such companies should be taxed. This paper identifies that role and investigates what is actually known about where these companies’ shareholders reside

Since the early 1990s the issue of fiscal transparency has attracted increasing attention from international institutions, governments, and NGO's concerned with budgets and fiscal policy reform. This Article offers a critical analysis of the meaning and purposes of fiscal transparency in light...

The world today finds itself in a recession. The global recession was caused by unsustainable borrowing provoked by the self destructive and incoherent “war on terror” in concert with irresponsible bank lending – bad debt. These policies have repercussions beyond the immediate recession:...

Structured finance transactions are increasingly under scrutiny by tax authorities. They are suspicious that the driving motivation behind such transactions is tax avoidance. This places all structured finance transactions in a spotlight of tax uncertainty and makes them a source of potential...

This paper is a submission to the International Accounting Standards Board (IASB) on proposed Draft Income Tax Statement EB/2009/02. This submission analyzes the effect of the proposed treatment of tax uncertainties, which create potential contraventions of constitutions world-wide if...

Tax Risk Management requires seven steps to ensure complete compliance by taxpayers, in an international environment where tax authorities are becoming better equipped and organized in closing tax gaps. Part of the process of tax authorities is the formation of Large Tax Units that expect to...

This paper considers the structure of the transfer pricing rules in tax treaties and their modern development in the Transfer Pricing Guidelines. It discusses how tax structuring and restructuring relying on the guidelines occurred to reduce residence and source taxation and commences an...

In a reversal from its historical roots, the United States income tax system now taxes income from labor significantly more heavily than income from capital. It does so not only facially, through explicit preferences for income from capital, but also more subtly, through more hidden features of...

Border tax adjustments (BTAs) may be able to alleviate concerns of reduced competitiveness for countries introducing environmental taxes and standards, while limiting the risk of companies relocating to developing countries to exploit lax environmental regimes - known as leakage. However, the...

The existence of different tax regimes and corporate rates of income tax between countries has given rise to international tax arbitrage and transfer pricing schemes. The objective of these schemes has been to minimize income tax expense and tax liabilities of multinational enterprises (MNEs)....