The transformation of international tax

R Mason - American Journal of International Law, 2020 - cambridge.org
The recession of 2008 precipitated a political crisis that motivated an unprecedented
international project to curb corporate tax dodging. This Article argues, contrary to dominant …

The state administration of international tax avoidance

O Marian - Harv. Bus. L. Rev., 2017 - HeinOnline
To explain these arguments, this Article uses an original dataset. In November 2014,
hundreds of advance tax agreement (ATAs) issued by Luxembourg's Administration des …

[HTML][HTML] Group subsidiaries, tax minimization and offshore financial centres: Mapping organizational structures to establish the 'in-betweener'advantage

R Phillips, H Petersen, R Palan - Journal of International Business Policy, 2021 - Springer
International business and public policy research have examined the techniques that
multinational enterprises (MNEs) use to shift revenues to subsidiaries in offshore financial …

Formulary Apportionment in the US International Income Tax System: Putting Lipstick on a Pig?

JC Fleming Jr, RJ Peroni, SE Shay - Mich. J. Int'l L., 2014 - HeinOnline
An affiliated corporate group consists of two or more corporations linked by sufficient stock
ownership to cause them to function as an economic unit instead of as independent …

Corporate social responsibility of US‐listed firms headquartered in tax havens

D Lee - Strategic Management Journal, 2020 - Wiley Online Library
Abstract Research Summary Using 138 firm‐year observations for 46 US‐listed firms
headquartered in tax havens from 2004 to 2013, this study employs a matched‐sample …

Treaties in the Aftermath of BEPS

Y Brauner - Brook. J. Int'l L., 2015 - HeinOnline
Treaties in the Aftermath of BEPS an almost respectable faqade. Yet, they are also elusive
legal instruments and lack a consensus about their true nature and purpose. Tax …

Taxing data

O Marian - BYU L. Rev., 2021 - HeinOnline
One of the main ways by which governments raise revenue is by taxing the economic
components of income. 1 This has been the case since the early twentieth century. 2 …

Arbitrage spaces in the offshore world: Layering,'fuses' and partitioning of the legal structure of modern firms

R Palan, H Petersen, R Phillips - Environment and Planning …, 2023 - journals.sagepub.com
In this article, we discuss the way offshore financial centres are used by the multi-subsidiary,
multi-jurisdictional group structure known as the 'multinational enterprise'to arbitrage …

Transacting in data: Tax, privacy, and the new economy

AB Thimmesch - Denv. L. Rev., 2016 - HeinOnline
The technological developments of recent decades have allowed companies to collect
staggering amounts of consumer data by offering" free" access to digital products like search …

Inter-Nation Equity Revisited

I Ozai - Colum. J. Tax L., 2020 - HeinOnline
States are on the verge of a new form of global competition. Some have taken unilateral
measures to tax multinational profits that they would typically not be able to tax, at least not …