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Boston College Law School

Banking and Finance Law

Commercial Law

2002

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One Nation Among Many: Policy Implications Of Cross-Border Tax Arbitrage, Diane M. Ring Dec 2002

One Nation Among Many: Policy Implications Of Cross-Border Tax Arbitrage, Diane M. Ring

Boston College Law School Faculty Papers

Cross-border tax arbitrage arises where a transaction is subject to two or more countries’ differing tax regimes. Conflicts between the tax rules create unique opportunities for the parties to engage in profitable tax planning – opportunities that would not be available if the transaction occurred entirely domestically in one of the countries. These opportunities have been a growing feature of the multi-jurisdictional business world and have raised issues concerning whether and how countries, such as the United States, should respond. This Article examines cross-border tax arbitrage in the context of both domestic tax policy and of other international tax issues, and ...