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International Vertical Equity, Adam H. Rosenzweig

Loyola University Chicago Law Journal

This Essay considers the role of equity in the international tax context. While much has been written about the importance of equity in the domestic context, the conversation around international tax has failed to recognize the importance of the concept of equity. While tax policy in the domestic context has historically prioritized equity over efficiency, tax policy in the international context has not equally prioritized equity, at least not in the same way. In particular, this Essay addresses this question by revisiting the classic and dominant theory of equity in international tax policy, inter-nation equity, and its traditional roots in …