The terms “enterprise,” “business” and “business profits” are ubiquitous in U.S. and international tax law yet they are often ill-defined and under-theorized, especially in their interaction with other regulatory areas. This U.S. Report, commissioned for a comparative volume on the...

This article examines the potential use of taxation to generate development funds in connection with the immigration of skilled immigrants from developing into developed countries, known as the "brain drain," if designed according to the principles of the new development agenda. It explains that...

This book is the first collection of independent legal scholarship exploring the relationship between tax, law and the quest for human development. While acknowledging fully the challenge of tax competition in a global economy, this book rejects calls to end taxation of mobile capital even if...

The grand illusion of a single, worldwide, tax system that will eliminate all international inefficiencies, and assist all the nations of the world to maximize their relative advantages, is, as commonly accepted, utopian. The tax, academic and professional, writing in the field of international...

M&A play a major role in the materialization of globalization, but it is just one of several challenges that globalization poses to international tax policy, all of which share two basic tensions that may have been present in the past, but have been significantly exacerbated in importance by...

For years the advent of the digital economy has left countries stumped in their attempt to tax income earned by foreign firms without physical presence within their jurisdiction. International organizations and their member countries have failed in their attempts to tweak the rules of the...