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Tax Incentives And Sub-Saharan Africa, Karen B. Brown 2021 Pepperdine University

Tax Incentives And Sub-Saharan Africa, Karen B. Brown

Pepperdine Law Review

The OECD’s Base Erosion Profit Shifting (BEPS) project has taken a powerful and welcome look at many of the tax avoidance strategies that proliferate in a world where multinational enterprises are in the business of exploiting gaps in the tax laws of different countries to minimize their ultimate tax bills. The focus on international consensus and prescriptions for reform has not been an unqualified good for the nations in Sub-Saharan Africa, which find themselves in the position of reacting to standards and taking on compliance burdens set without sufficient consideration of their special circumstances. Because the path for the ...


Front Matter (Letter From The Editor, Masthead, Etc.), 2021 San Jose State University

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


Designing A More Sustainable Global Tax System, Allison Christians 2021 McGill University, Faculty of Law

Designing A More Sustainable Global Tax System, Allison Christians

Dalhousie Law Journal

The international tax system incentivizes unsustainable business practices because it ignores the private profits created by externalizing human, societal, and environmental costs. This paper proposes a novel reform: applying living wage and externality assessment tools to the rules for establishing where income arises for tax purposes. To do so, I propose a method that is relatively complex but arguably more accurate (in tax terms) and a complementary but relatively simpler proxy method. I examine how each method would implicate treaty-based and domestic rules and processes and conclude that the proposed design provides a viable starting point to make the global ...


International Tax Law Between Loyalty, Exit, And Voice, TarcÍsio Diniz Magalhães 2021 University of Antwerp, Faculty of Law

International Tax Law Between Loyalty, Exit, And Voice, Tarcísio Diniz Magalhães

Dalhousie Law Journal

Discourse on the merits and pitfalls of multilateral cooperation for advancing justice in international tax law have recently re-emerged in the literature. Some tax scholars, even while criticizing global projects like the OECD/G20 initiatives on base erosion, profit shifting and the tax challenges arising from the digitalisation of the economy, insist that cooperative efforts herald a step in the right direction. Others contest the feasibility of international cooperation or its value for developing countries. Drawing on Albert Hirschman’s oft-cited framework for actor behaviour under institutional malperformance, this article shows that there are three alternatives for those discontented with ...


Cross-Border Tax Transparency: A Study Of Recent Policy Developments In Turkey, Leyla Ateş 2021 Altinbas University, Faculty of Law

Cross-Border Tax Transparency: A Study Of Recent Policy Developments In Turkey, Leyla Ateş

Dalhousie Law Journal

Transnational tax information cooperation has the crucial role of empowering tax administrations to collect tax revenues in full and on time, thereby narrowing the tax gap created by international evasion and avoidance. However, the adequacy of established transnational tax information exchange systems in combatting international tax evasion and avoidance has been severely criticized and a new wave of progress on transparency has started after the 2008 global economic crisis. In this direction, Turkey set cross-border tax transparency high on its political agenda. Though, Turkey has operationalized new transnational tax cooperation agreements very slowly. Furthermore, Turkey’s approach to exchanging information ...


Repurposing Pillar One Into An Incremental Global Tax For Sustainability: Some Blue Sky Thinking In The Midst Of Global Crisis, Jinyan Li, Sophie Chatel 2021 Osgoode Hall Law School of York University

Repurposing Pillar One Into An Incremental Global Tax For Sustainability: Some Blue Sky Thinking In The Midst Of Global Crisis, Jinyan Li, Sophie Chatel

Articles & Book Chapters

In this article, the authors make a case for repurposing the OECD Pillar One from a mechanism for reallocating taxing rights to a global tax on the largest and most profitable MNEs’ market-based profits. Such global tax would have the hybrid features of a net-basis corporate income tax and a turnover-basis digital services tax through a conversion formula that ensures a low-rate DST on sales can replicate a higher rate CIT on a country’s share of the profit determined using under the formulary allocation method. More importantly, the authors instill a common purpose of the international tax consensus – to ...


Repurposing Pillar One Into An Incremental Global Tax For Sustainability: A Collective Response To A Global Crisis, Jinyan Li, Sophie Chatel 2021 Osgoode Hall Law School of York University

Repurposing Pillar One Into An Incremental Global Tax For Sustainability: A Collective Response To A Global Crisis, Jinyan Li, Sophie Chatel

Articles & Book Chapters

This article proposes to repurpose the OECD/IF Pillar One Blueprint from a taxing rights reallocation mechanism into an incremental global tax for sustainability. With a common goal and DST-like feature for simplification, the proposal aims to ease the negotiation of essential and drastic simplifications required to deliver a workable solution.


International Tax, Margriet Lukkien, Christie Galinski, David Dingfa Liu, Aseem Chawla, Eugenio Romita, Guillermo Villsenor, Jorge Lopez, Star Q. Lopez 2021 Southern Methodist University

International Tax, Margriet Lukkien, Christie Galinski, David Dingfa Liu, Aseem Chawla, Eugenio Romita, Guillermo Villsenor, Jorge Lopez, Star Q. Lopez

The Year in Review

No abstract provided.


Lecture In Human Rights: Tax Policy, Global Economics, Labor And Justice In Light Of Covid-19, Reuven S. Avi-Yonah 2021 University of Michigan Law School

Lecture In Human Rights: Tax Policy, Global Economics, Labor And Justice In Light Of Covid-19, Reuven S. Avi-Yonah

Articles

International Tax Law has extensive ramifications on the wealth gap between wealthy developed nations and poor developing nations. This divide in prosperity has been made clear again in the global response to the COVID-19 pandemic. Developing nations are currently ill-equipped to adapt to, and regulate, an equitable system of taxation on a domestic level. A further challenge is the difficulty of ensuring that foreign investors, especially multinational corporations, are able to comply with tax regulations. Developed nations such as the United States and members of the European Union must continue to work with developing nations to reduce tax evasion and ...


Tax Planning For Foreign Expansion By U.S. Petroleum Companies, Martin Van Brauman 2021 United States Internal Revenue Service

Tax Planning For Foreign Expansion By U.S. Petroleum Companies, Martin Van Brauman

Journal of Natural Resources & Environmental Law

No abstract provided.


Federal Tax Considerations In Foreign Oil And Gas Operations By Domestic Oil Companies, Martin M. Van Braumen 2021 United States Internal Revenue Service

Federal Tax Considerations In Foreign Oil And Gas Operations By Domestic Oil Companies, Martin M. Van Braumen

Journal of Natural Resources & Environmental Law

No abstract provided.


Federalizing Tax Justice, Reuven Avi-Yonah, Orli Avi-Yonah, Nir Fishbien, Hayian Xu 2021 University of Michigan Law School

Federalizing Tax Justice, Reuven Avi-Yonah, Orli Avi-Yonah, Nir Fishbien, Hayian Xu

Articles

The United States is the only large federal country that does not have an explicit way to reduce the economic disparities among more and less developed regions. In Germany, for example, federal revenues are distributed by a formula that takes into account the relative level of wealth of each state (the so-called Finanzausgleich, or fiscal equalization). Similar mechanisms are found in Australia, Canada, India, and other large federal countries. The United States, on the other hand, has no such explicit redistribution. Each state is generally considered equal and sovereign, and the federal government does not distribute revenues to equalize the ...


Summaries From The 2020 36th Annual Tei-Sjsu High Tech Tax Institute, Charlene Kliatchko, Jane Lei CPA, Hanna Shatanionak CPA, Liubov (Luba) Shilkova, Xiaoyue Tan 2021 San Jose State University

Summaries From The 2020 36th Annual Tei-Sjsu High Tech Tax Institute, Charlene Kliatchko, Jane Lei Cpa, Hanna Shatanionak Cpa, Liubov (Luba) Shilkova, Xiaoyue Tan

The Contemporary Tax Journal

No abstract provided.


Table Of Contents, Seattle University Law Review 2021 Seattle University School of Law

Table Of Contents, Seattle University Law Review

Seattle University Law Review

Table of Contents


Are Digital Services Taxes Imposed By Other Countries Creditable Under Irc Section 903? Yes. But, What If The Opposite Is True?, Charles Edward Andrew Lincoln IV 2021 Touro College Jacob D. Fuchsberg Law Center

Are Digital Services Taxes Imposed By Other Countries Creditable Under Irc Section 903? Yes. But, What If The Opposite Is True?, Charles Edward Andrew Lincoln Iv

Touro Law Review

No abstract provided.


Origin And Differentiation In International Income Allocation, Ivan Ozai 2021 Osgoode Hall Law School of York University

Origin And Differentiation In International Income Allocation, Ivan Ozai

Articles & Book Chapters

The present international tax rules are typically justified by origin-based theories. These theories align countries’ tax entitlements with the geographical location of the economic factors that contribute to the creation of income. Two recent phenomena have rendered origin-based approaches limited in scope. First, the economic integration of multinational corporations and the relevance of intangibles have made it infeasible to precisely pinpoint the factors contributing to the generation of income. Second, the growing disputes between countries about which economic factors should be considered relevant for sharing the international tax base have recently led to increased consideration of distributional consequences, thus moving ...


The 2021 Corporate Transparency Act: The Next Frontier Of U.S. Tax Transparency And Data Debates, Diane Ring 2021 Boston College

The 2021 Corporate Transparency Act: The Next Frontier Of U.S. Tax Transparency And Data Debates, Diane Ring

Boston College Law School Faculty Papers

As we enter the third decade of the twenty-first century, twin revolutions—one in digital data, the other in international tax—are well underway. Both are global phenomena with independent momentum, but in practice they intersect and often find themselves in tension. Increasingly pervasive digital data has prompted major debates over privacy, artificial intelligence, government overreach, and digital crime. The past year has witnessed growing concern and litigation regarding expanded data collection and use in both the private and public sectors, with the COVID-19 pandemic igniting clashes between public health and privacy. At the same time, international tax trends have ...


A Major Simplification Of The Oecd’S Pillar 1 Proposal, Michael J. Graetz 2021 Columbia Law School

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.


Enough Is As Good As A Feast, Noah C. Chauvin 2020 Seattle University School of Law

Enough Is As Good As A Feast, Noah C. Chauvin

Seattle University Law Review

Ipse Dixit, the podcast on legal scholarship, provides a valuable service to the legal community and particularly to the legal academy. The podcast’s hosts skillfully interview guests about their legal and law-related scholarship, helping those guests communicate their ideas clearly and concisely. In this review essay, I argue that Ipse Dixit has made a major contribution to legal scholarship by demonstrating in its interview episodes that law review articles are neither the only nor the best way of communicating scholarly ideas. This contribution should be considered “scholarship,” because one of the primary goals of scholarship is to communicate new ...


Table Of Contents, Seattle University Law Review 2020 Seattle University School of Law

Table Of Contents, Seattle University Law Review

Seattle University Law Review

Table of Contents


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