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Full-Text Articles in Law

Tax Harmony: The Promise And Pitfalls Of The Global Minimum Tax, Reuven Avi-Yonah, Young Ran (Christine) Kim Aug 2022

Tax Harmony: The Promise And Pitfalls Of The Global Minimum Tax, Reuven Avi-Yonah, Young Ran (Christine) Kim

Michigan Journal of International Law

The rise of globalization has become a double-edged sword for countries seeking to implement a beneficial tax policy. On one hand, there are increased opportunities for attracting foreign capital and the benefits that increased jobs and tax revenue brings to a society. However, there is also much more tax competition among countries to attract foreign capital and investment. As tax competition has grown, effective corporate tax rates have continued to be cut, creating a “race-to-the-bottom” issue.

In 2021, 137 countries forming the OECD/G20 Inclusive Framework on BEPS passed a major milestone in reforming international tax by successfully introducing the framework …


International Tax Law Between Loyalty, Exit, And Voice, Tarcísio Diniz Magalhães Jun 2021

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 the status …


The Globalization Of Corporate Tax Reform, Steven A. Bank May 2013

The Globalization Of Corporate Tax Reform, Steven A. Bank

Pepperdine Law Review

With the growth of multinational corporations and its effect on corporate tax revenues, it is not surprising that international tax reform is a major part of President Obama’s Framework for Business Tax Reform as he begins his second term. Noticeably missing from this and other discussions of the major structural reform proposals, however, is any mention of the influence and importance of international corporate tax reform efforts. Although the concern over corporate tax evasion is especially pronounced in the U.S., the "decentering" of multinational corporations and corporate tax revenues is by no means an exclusively American problem. Around the world, …