The current age of globalization can be distinguished from the previous one by the much higher mobility of capital than labor. The mobility of capital has led to tax competition, in which sovereign countries lower their tax rates on income earned by foreigners within their borders in order to...

The current age of globalization can be distinguished from the previous one by the much higher mobility of capital than labor. The mobility of capital has led to tax competition, in which sovereign countries lower their tax rates on income earned by foreigners within their borders in order to...

Twenty years ago I wrote “Globalization, Tax Competition, and the Fiscal Crisis of the Welfare State” (113 Harv. L. Rev. 1573 (2000)), which argued that “[t]he current age of globalization can be distinguished from the previous one (from 1870 to 1914) by the much higher mobility of capital...

This paper addresses three questions: 1. Is there evidence that the tax systems of different countries have converged (i.e., become more similar) in the period 1980-2010? 2. If so, what is the explanation for this convergence? 3. Is convergence a positive or negative development?

The global corporate minimum tax (GLoBE) as embodied in Pillar 2 of the OECD/IF BEPS 2.0 proposal was set in October 2021 at 15% of the financial statement income of within scope MNEs. That is also the rate and the base of the new US corporate alternative minimum tax (CAMT). The Single Tax...

The past decade has witnessed the creation of a new international tax regime (ITR). The original ITR was created a century ago by the League of Nations. Until the 1980s, it functioned reasonably well, and prevented most instances of double taxation and double non-taxation by allocating...