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Articles 1 - 3 of 3
Full-Text Articles in Law
Beyond The "Made In America Tax Plan": Gilti And International Tax Cooperation's Next Golden Age, Steven Dean
Beyond The "Made In America Tax Plan": Gilti And International Tax Cooperation's Next Golden Age, Steven Dean
Faculty Scholarship
Tumultuous times can be particularly difficult for the vulnerable. That may be no less true in the international tax context than it is elsewhere, but disruptive change can also open the door to greater participation by, and rewards for, those long treated as outsiders. With international tax cooperation's first golden age receding into history, new priorities have begun to take root. Unprecedented challenges buffet the international tax regime, suggesting that its future may depend less on its capacity to shield businesses from taxation than on its ability to find common ground among very different states.
International tax cooperation has long …
Delaware's Global Competitiveness, William J. Moon
Delaware's Global Competitiveness, William J. Moon
Faculty Scholarship
For about a hundred years, Delaware has been the leading jurisdiction for corporate law in the United States. The state, which deliberately embarked on a mission to build a haven for corporate law in the early twentieth century, now supplies corporate charters to over two thirds of Fortune 500 companies and a growing share of closely held companies. But Delaware’s domestic dominance masks the important and yet underexamined issue of whether Delaware maintains its competitive edge globally.
This Article examines Delaware’s global competitiveness, documenting Delaware’s surprising weakness competing in the emerging international market for corporate charters. It does so principally …
A Major Simplification Of The Oecd’S Pillar 1 Proposal, Michael J. Graetz
A Major Simplification Of The Oecd’S Pillar 1 Proposal, Michael J. Graetz
Faculty Scholarship
In this report, Graetz suggests major modifications to the OECD’s pillar 1 blueprint proposal to create a new taxing right for multinational digital income and some product sales that would greatly simplify the proposal. The modifications rely on readily available existing financial information and would achieve certainty in the application of pillar 1, while adhering to its fundamental structure and policies.