Introduction / Reuven S. Avi-Yonah & Michael Lang -- European constitutional intergration : the case of direct taxation / Gianluigi Bizioli & Claudio Sacheto -- There is life in the old dog yet : horizontal comparability and the establishment of the internal market / Michael Lang --...

ECJ direct tax cases and domestic constitutional principles: an overview / Claudio Sacchetto -- Double taxation and EC law / Michael Lang -- Nondiscrimination from the perspective of the OECD model and the EC treaty: structural and conceptual issues / Kees van Raad -- The US Supreme Court's...

"Encapsulating the multitude of challenges faced by the international corporate tax regime, this timely Research Handbook provides an in-depth comparative legal analysis of corporate income tax as it is practiced across the world. Beginning with four foundational chapters exploring the purpose...

Tax competition is with us to stay, and the drive toward territorial taxation of multinationals will continue. Ultimately, it makes sense to tax corporations on a source basis because corporate residence is not very meaningful. But if the correct reforms to CFC rules are undertaken together with...

Tax Cuts and Jobs Act (“TCJA”) signed into law by President Trump on 22 December 2017 contains multiple provisions that significantly impact Europe and the way European corporations are being taxed by the US. The US corporate tax rate is set to be 21% (reduced from 35%). Most importantly,...

For the past thirty-five years, the debate on fundamental tax reform in the United States has centered on whether some type of consumption tax would replace all or part of the federal income tax. In my opinion, this debate has now been decided. Given recent budgetary developments and the...

This article reviews recent US proposals to amend the US Controlled Foreign Corporation (CFC) rules, also known as Subpart F. It places the US debate in a comparative perspective by describing how the US proposals fit in with developments in other countries that have CFC rules