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,...

U.S. Treasury officials and members of Congress from both parties have expressed concern that the European Commission's current state aid investigations are disproportionately targeting U.S.-based multinational enterprises. At the same time, a Treasury official recently suggested in...

This Article compares the ways in which the United States and the European Union limit the ability of state-level entities to subsidize their own residents, whether through direct subsidies or through tax expenditures. It uses four recent charitable giving cases decided by the European Court of...

This article proposes that U.S. international tax policy analysis must take into account non-tax regulation, which is generally disregarded in international tax policy analysis. Structural features of non-tax regulatory regimes will be shown to have significant implications for fundamental...

Part IV examines FATCA withholding liability for withholdable payments under Code Secs. 1471 and 1472, and provides a nine-point analysis—each of which must be answered affirmatively for the new 30-percent withholding tax to apply

Over the past two and a half years, the international tax community has focused on the Base Erosion and Profit Shifting Project (BEPS project) undertaken by the Organisation for Economic Co-operation and Development (OECD) at the behest of the G20. According to the OECD, the resulting 2015...

U.S. immigrants often have the desire to give back in order to promote welfare in their countries of origin. The U.S. income tax law may permit a deduction for their contributions (IRC Sec. 170). A deduction is available when contributions are made to certain U.S. non-profit entities. These...

We examine the global equity supply chains of U.S. multinationals to explore how tax and nontax country characteristics affect whether firms use foreign holding companies and where they locate them. We find that U.S. multinationals supply equity from headquarters to their foreign operating...