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Full-Text Articles in Taxation-Transnational
Stabilizing “Pillar One”: Corporate Profit Reallocation In An Uncertain Environment, Itai Grinberg
Stabilizing “Pillar One”: Corporate Profit Reallocation In An Uncertain Environment, Itai Grinberg
Georgetown Law Faculty Publications and Other Works
This paper is about how the world reestablishes international tax order.
The paper focuses on the OECD’s work on profit reallocation and asks whether this multilateral effort can be successful in stabilizing the international tax system. The analysis centers on the current leading concepts for reallocating profit among jurisdictions under what is known as “Pillar One” of the OECD work programme. To analyze whether any Pillar One concept can be turned into a stable multilateral regime, it is necessary to specify certain elements of what a proposal to reallocate profits might entail. Accordingly, this paper sets out two strawman proposals. …
The Battle Over Taxing Offshore Accounts, Itai Grinberg
The Battle Over Taxing Offshore Accounts, Itai Grinberg
Georgetown Law Faculty Publications and Other Works
The international tax system is in the midst of a contest between automatic information reporting and anonymous withholding models for ensuring that nations have the ability to tax offshore accounts. At stake is the extent of many countries’ capacity to tax investment income of individuals and profits of closely held businesses through an income tax in an increasingly financially integrated world.
Incongruent initiatives of the European Union, the Organisation for Economic Cooperation and Development (OECD), Switzerland, and the United States together represent an emerging international regime in which financial institutions act to facilitate countries’ ability to tax their residents’ offshore …