If one listens to what Democratic and Republican candidates for president are saying on the campaign trail, the chances for tax reform in 2017 and beyond appear to be minimal. To pass tax reform, a bipartisan approach is essential, because even if we have a Republican president and Republican...

This paper aims to suggest two proposals for solving the current problems of the U.S. international tax regime that can be implemented on a bipartisan basis. To do so, the first section below will provide some context. The next section will survey recent reform proposals by both U.S....

Today, more than ever the battle against tax evasion is taking a center stage in the global political agenda. Hence, leading countries are intensifying their efforts and adding tools to assist in the pursuit of information concerning the international business activities of their taxpayers. The...

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,...

Section 877A was enacted in 2008 to impose a significant price on US citizens who expatriate. But the price was not right. The quarterly data on expatriations (published in the Federal Register since 1998) show an increasing trend since 2008. For example, 3,422 Americans expatriated in 2022, and...

This essay argues that the current COVID-19 crisis is the perfect time to make revenue-raising reforms to state corporate income taxes — reforms that would have been desirable policy improvements even during an economic upturn, but that are even more clearly good policy moves in light of the...

The Tax Cuts and Jobs Act (TCJA) includes several provisions that may be viewed as potential violations of US tax treaties. However, most of those potential violations, such as new IRC section 951A and to a large extent new IRC section 59A, are covered by the Savings Clause (US model article...