U.S. taxpayers and the IRS increasingly have to take into account the interactions between U.S. and foreign laws, but they have paid little attention to the administrative law backgrounds of foreign tax laws. In a growing range of cases, the need for such attention has become urgent. This...

Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International's corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages,...

The US Section 301 trade actions against DSTs were strikingly effective in the short term. Section 301, however, is ill suited as a process for challenging taxes of other countries and lacks legitimacy. The sovereign power to tax is very broad and there is insufficient international agreement on...

The main objective of this paper is to analyze the current developments of international exchange of information taking into account the legitimacy of these instruments vis-á-vis the taxpayer including the protection of taxpayer's rights. The taxpayer rights addressed in this article are the...

The East African Community (EAC) is working towards establishing deeper integrationbetween its six partner states. The EAC partner states are: Burundi, Kenya, Rwanda,South Sudan, Tanzania and Uganda. This paper analyses the lessons the EuropeanUnion may offer the EAC in guarding against base...

This article analyses the ECJ decision in Hornbach-Baumarkt (C-382/16) from 31 May 2018 and its implications for the transfer pricing legislations of EU Member States. First, to argue that cross-border transactions targeted by the arm’s length principle are comparable to purely domestic ones,...

The East African Community (EAC) is working towards establishing deeper integration between its six partner states. The EAC partner states are: Burundi, Kenya, Rwanda, South Sudan, Tanzania and Uganda. This paper analyses the lessons the European Union may offer the EAC in guarding against base...

This study was developed based on the IBFD EU Task Force's submission within the framework of the European Commission 2021 public consultation on the use of shell entities and arrangements for tax purposes. The analysis of the broad ramifications of this central issue within corporate tax law...