Taxation-Transnational Commons^™

Mandating Fluoride: A Constitutional Exercise Of Police Power, Anita Jahangiri

Seattle University Law Review

This Note addresses the ongoing debate over fluoridation: the regulation of fluoride levels in public water systems. Extensive research indicates fluoridation, when regulated at the recommended concentration, is both safe and highly effective in preventing dental caries. Better known as cavities, dental caries is a preventable yet widespread health issue that disproportionately affects low-income populations. Reducing dental health disparities among economic classes is a pressing public health issue. Fluoridation is not merely a policy option, but a critical, proven tool to address such disparities and uphold the collective welfare of Washingtonians. This Note focuses on fluoridation as a public health …

Neurodiversity In The Courtroom: Expanding Jury Service Accessibility Beyond Physical Disability, Samantha L. Mabe

Seattle University Law Review

The Americans with Disabilities Act has required equal access to jury service for decades; however, efforts to accommodate jurors with disabilities have been slow to develop beyond some minor accommodations for physical disabilities. While neurodivergent people frequently struggle to navigate a world catered toward neurotypical people, jury service remains inaccessible for many neurodivergent people who need accommodations to attend trial and engage in jury deliberations. If courts and advocates do not consider how to develop accommodations to secure the service of neurodivergent jurors, they will miss out on the unique skillsets that neurodivergent people can bring to resolving disputes.

Disabled …

The Contemporary Tax Journal Volume 13, No. 2 – Winter 2024

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal’S Interview With Mr. David Forst, Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

Key Changes In The Final And Proposed Digital Content And Cloud Computing Regulations, David Forst, Kris Hatch

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Legislative Update – Tax And Non–Tax, Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: What’S New With Staking And Mining?, Yamilette Gonzalez

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: What Is Not In The First Final § 6045 Regulations?, Jacob Myers Cpa

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: What Happens When You’Re Paid In Crypto?, Weng Ng

The Contemporary Tax Journal

No abstract provided.

Sjsu Certificate In Advanced Tax Practice Information

The Contemporary Tax Journal

No abstract provided.

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

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Overview Of Blockchain Technology And Why It Matters For Tax, Sviatlana Yakavets

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Putting The Final 6045 Regulations And Form 1099-Da Into Practice, Raymond Clark

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Ensuring Widespread Implementation Of The Crypto-Asset Reporting Framework (Carf), Jing Luo

The Contemporary Tax Journal

No abstract provided.

From Relic To Relevance, The Resurgence Of Tariffs, Reuven S. Avi-Yonah, Doron Narotzki, Tamir Shanan

Law & Economics Working Papers

Modern legal scholarship has largely relegated tariffs to economic analysis, overlooking their legal and policy significance. This article challenges that view by examining tariffs as a potential pillar of fiscal policy, exploring their viability as a revenue source alongside or in place of traditional income and corporate taxation. While historically central to U.S. government funding, tariffs diminished in importance with the rise of income taxation and trade liberalization. However, their recent resurgence as a tool for trade protection raises broader questions about their role in national economic strategy. This article critically assesses the feasibility of a tariff-based tax system, drawing …

Should The Oecd Accept Gilti As A Valid Iir?, Reuven S. Avi-Yonah

Articles

On June 26 Treasury Secretary Scott Bessent announced a deal with the G7 to accept the global intangible low-taxed income tax as a valid income inclusion rule tax and not apply the undertaxed profits rule to U.S. multinational enterprises. Bessent said a “joint understanding” among the United States and other countries will be announced soon. “OECD pillar 2 taxes will not apply to U.S. companies, and we will work cooperatively to implement this agreement across the OECD-G20 inclusive framework in coming weeks and months,” Bessent wrote. Soon after, Senate Finance Committee Chair Mike Crapo, RIdaho, and House Ways and Means …

Proposed Cloud Services Sourcing Rule: The Right Direction, Reuven Avi-Yonah, Jeffery M. Kadet, Karen Sam

Articles

This past January, in conjunction with the issuance of a final regulation (T.D. 10022) that treats income from defined cloud transactions as income from services, Treasury and the IRS released a proposed regulation (REG-107420-24) on the sourcing of that income. In 2019 a Treasury official had asked the tax community for feedback on whether specific cloud transaction sourcing rules were needed, and the preamble to a 2019 proposed regulation asked for comments on “administrable rules for sourcing income from cloud transactions in a manner consistent with sections 861 through 865.” The feedback was “split almost evenly with regard to whether …

No Trade Wars Without Taxation -Who's To Blame, And What Comes Next?, Domenico Imparato, Reuven S. Avi-Yonah, Doron Narotzki

Law & Economics Working Papers

As tariff policy once again shapes U.S. trade strategy, this article makes a foundational claim: trade wars are, at their core, tax wars. Against the backdrop of escalating economic tensions with the United States’ trade partners, this article argues that tariffs cannot be understood apart from the fiscal architecture that sustains them. What appears to be protectionism often masks deeper structural asymmetries in the U.S. tax system.

The discussion proceeds through three interrelated dimensions: reshoring production, promoting fair trade, and raising revenue. In each, the interaction between tariffs and the tax system reveals deeper distortions. U.S. export mechanisms such as …

Where Intangibles Travel: Essays On The Tax-Motivated Geography Of Innovation And Capital, Xuerui Kou

Dissertations and Doctoral Documents, University of Nebraska-Lincoln, 2023–

This dissertation explores how taxation and institutional environments shape the global strategies of United States multinational enterprises (MNEs), with a particular focus on intangible assets and the cross-border allocation of innovation. Positioned at the intersection of international trade, public economics, and innovation studies, the three chapters collectively examine firm responses to international tax incentives and regulatory asymmetries.

Chapter 1 introduces the motivation and theoretical foundations of the dissertation, reviews related literature, and outlines the core research questions and empirical strategies. It highlights the increasing policy and academic interest in the geographic mobility of intangible capital, particularly in the context of …

Smu Launches International Tax Research Initiative With Grant From The Tax Academy Of Singapore, Singapore Management University

SMU Press Releases and News

Singapore Management University (SMU) Yong Pung How School of Law (YPHSL) and Tax Academy of Singapore announced the establishment of the Singapore Tax Academy Research Initiative (STARI) which will be undertaken by YPHSL’s Centre for Commercial Law in Asia. Supported by a grant from the Tax Academy of Singapore, this initiative aims to both contribute to the international tax academic community and serve the body of tax professionals in Singapore through three main streams of work: 1) conduct world-class international tax research; 2) develop local academic capacity in taxation; and 3) build links with international thought-leaders in taxation.