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Articles 1 - 4 of 4
Full-Text Articles in Law
International Taxation In An Era Of Digital Disruption: Analyzing The Current Debate, Itai Grinberg
International Taxation In An Era Of Digital Disruption: Analyzing The Current Debate, Itai Grinberg
Georgetown Law Faculty Publications and Other Works
The “taxation of the digital economy” is currently at the top of the global international tax policymaking agenda. A core claim some European governments are advancing is that user data or user participation in the digital economy justifies a gross tax on digital receipts, new profit attribution criteria, or a special formulary apportionment factor in a future formulary regime targeted specifically at the “digital economy.” Just a couple years ago the OECD undertook an evaluation of whether the digital economy can (or should) be “ring-fenced” as part of the BEPS project, and concluded that it neither can be nor should …
User Participation In Value Creation, Itai Grinberg
User Participation In Value Creation, Itai Grinberg
Georgetown Law Faculty Publications and Other Works
This article examines HM Treasury’s proposal to account for the active participation of users in value creation in certain digital platforms. The first key question is whether there is any reason to believe, as HM Treasury suggests, that users only meaningfully or actively contribute to value creation in the context of certain digital platforms. The article accordingly explores the factors HM Treasury sets out for the attribution of income to active user participation, including features such as network effects, multisided business models, and a lack of physical presence in the jurisdiction of the user. It concludes that if a user …
The Definitions Of Income, John R. Brooks
The Definitions Of Income, John R. Brooks
Georgetown Law Faculty Publications and Other Works
What is income? It’s a seemingly simple question that’s surprisingly hard to answer. Income is the basis for assigning tax burdens, for distributing transfers, and for broader normative issues of inequality and justice. Yet we lack a shared conception of income, and a pure, rigorous definition of income is impossible. In this Article I review the intellectual history of the income concept among tax and fiscal theorists to show the difficulty of the problem, and also to show that some important debates about what’s proper under an income tax can be explained instead as arguments over competing income definitions that …
Curing The Cost Disease: Legal Education, Legal Services, And The Role Of Income-Contingent Loans, John R. Brooks
Curing The Cost Disease: Legal Education, Legal Services, And The Role Of Income-Contingent Loans, John R. Brooks
Georgetown Law Faculty Publications and Other Works
The costs of both legal education and legal services have been rising steadily for decades. This is because they share a common root: the constant above-inflation growth in the cost of labor-intensive goods and services known as the “cost disease.” The cost disease story roots cost growth not in market failure or bureaucratic waste, but in natural, even healthy, economic forces—productivity and wage growth. Because the source of this cost growth is productivity growth, the nature of the cost disease is such that an economy as a whole can afford these rising costs. But in a world of deep income …