Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

Conventional wisdom explains tax competition as an external constraint on lawmaking that can only be curbed through multinational cooperative efforts to eliminate beggar-thy-neighbor tax policies. But the international tax reform plan recently introduced by Senator Baucus squarely confronts this...

Some countries are undertaking, and others considering, self-examination rules to detect whether proposed tax reforms might have a negative impact on tax policy or economic outcomes in less affluent countries. The impetus for this kind of analysis is a loosely articulated idea that states may...

Tax reform is a constant process in most nations as governments continuously revisit their tax regimes in response to economic, social, and political forces. Domestic legislative processes are the most obvious source of change in the tax system in any independent nation, but international...

In popular discourse, tax evasion by wealthy individuals is conflated with tax avoidance by multinational corporations to tell a single story about tax dodging and its negative impact on society. But conflating avoidance and evasion muddies the tax policy waters in important ways by turning...

The OECD recently emerged as the site of unprecedented, multilateral, and seemingly high-stakes negotiations about the future of international business income taxation. Judging by the political resources deployed in these negotiations, international tax has entered unchartered territory....

We have several kinds of measures for mitigating or eliminating international double taxation and stimulating international trade. Some of them are unilateral, the others are bilateral, and still others are multilateral. A natural question here: why we have all these measures? The answer lies in...

Tax treaties are often seen as a means to mitigate fierce tax competition. We challenge this view by arguing that taxes on passive income reduce e↵ective average tax rates, and induce neighbouring countries to react by reducing bilateral tax rates. As opposed to traditional tax competition,...

This study provides an interdisciplinary analysis of firm theory and international tax law, applied within a framework of hypothetical illustrations of prototypical multinational enterprises. The study finds that the construct and interpretation of different norms of international tax law...