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Full-Text Articles in Law

Constructive Dialogue: Beps And The Tcja, Reuven S. Avi-Yonah Feb 2020

Constructive Dialogue: Beps And The Tcja, Reuven S. Avi-Yonah

Law & Economics Working Papers

US international tax law is commonly conceived as developed in the US and influencing the development of other countries' international tax law. This paper will argue that in the case of the TCJA, the US legislation was heavily influenced by the OECD BEPS project, and that the continuing OECD work in Pillars I and II is likely to have a similar influence on the future development of US international tax law.


What Is Unilateralism In International Taxation?, Wei Cui Jan 2020

What Is Unilateralism In International Taxation?, Wei Cui

All Faculty Publications

The OECD recently emerged as the site of unprecedented, multilateral, and seemingly high-stakes negotiations about the future of international business income taxation. Judging by the political resources deployed in these negotiations, international tax has entered unchartered territory. Professor Ruth Mason offers a timely and balanced portrayal of the OECD process so far. But explanations of this process remain highly contestable. On the one hand, international institutions that address externalities from uncoordinated actions and produce mutual benefits for participating nations can be highly stable. On the other hand, the OECD has struggled, whether in its BEPS (Base Erosion and Profit Shifting) …


Uniform International Tax Collection And Distribution For Global Development, A Utopian Beps Alternative, Henry Ordower Jan 2020

Uniform International Tax Collection And Distribution For Global Development, A Utopian Beps Alternative, Henry Ordower

All Faculty Scholarship

Under the guise of compelling multinational enterprises (MNEs) to pay their fair share of income taxes, the OECD and other multinational agencies have introduced proposals to prevent MNEs from eroding the income tax base of developed economies by continuing to shift income artificially to low or zero tax jurisdictions. Some of the proposals have garnered substantial multinational support, including recent support from the new U.S. presidential administration for a global minimum tax. This Article reviews many of those international proposals. The proposals tend to concentrate the incremental tax revenue from the prevention of base erosion into the treasuries of the …