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A Shrouded Remedy: Increasing Transparency In The Irs Advance Pricing And Mutual Agreement Program By Releasing Redacted Advance Pricing Agreements And Increasing Administrative Disclosures, Blake L. Currey
San Diego Law Review
This Comment examines the current state of the IRS’s handling of pricing agreements within the APMA Program, arguing that the IRS should improve the Program by increasing its transparency to coincide with the additional resources being devoted to the Program, the IRS’s elevating transfer pricing enforcement, and the modern valuation challenges in transfer pricing. Part II further introduces transfer pricing and the arm’s length standard, and Part III examines the recent performance of the APMA Program. Part IV explores the Program’s troubling lack of transparency. Part V analyzes the legal and financial interests implicated by improving the Program’s transparency, arguing …
Brown V. Board In The World: How The Global Turn Matters For School Reform, Human Rights, And Legal Knowledlge, Martha Minow
Brown V. Board In The World: How The Global Turn Matters For School Reform, Human Rights, And Legal Knowledlge, Martha Minow
San Diego Law Review
Global perspectives can contribute to our understandings of any one nation’s laws and decisions. In this light, America’s educational landmark, Brown v. Board of Education, matters not just for the United States but around the world. Inside the United States, a cottage industry of academic scholars studies the influence of Brown where the decision’s impact reaches well beyond racial desegregation of schools. The litigation has by now a well-known and complicated relationship to actual racial integration within American schools, as the case perhaps exacerbated tensions and slowed otherwise gradual reform, and perhaps at the same time galvanized the social movement …