Published: 2021-03-01
Introduction
A Tribute to Michael K. Friel
621–624
AbstractIt is a great honor for me to edit this issue of the Florida Tax Review in honor of not only one of the greatest educators I have known...
Articles
In Lieu of GILTI
Excessive Unrepatriated Earnings
625–676
AbstractPrior to the 2017 tax reform (TCJA), with a few exceptions, the United States only taxed the foreign income of its domestic corporations when...
Education Has Been "Dumbed Down" in Tax Reform
677–704
AbstractWith promises of “Make America Great Again” and tax reform for “middle-class” Americans, the current federal government administration has...
Focus on the Facts
705–723
AbstractThis Essay highlights the importance of the data analysis process (the curation) as part of analyzing and determining the strength of tax...
The Future of Profit Splits
724–754
AbstractIn a highly integrated world where new technologies are disrupting the market, taxation and transfer pricing have gained a lot of attention...
Simplification in Transfer Pricing
A Plea for the Enactment of Rebuttable Predetermined Margins and Methods Within Developing Countries
755–788
AbstractIt is the aim of this contribution to sustain that, despite the inherent complexity that the enforcement of the arm’s length rationale entails,...
On the Fragility of the International Taxation Legal System
789–849
AbstractThis Article focuses on the OECD’s work on harmful tax competition to
demonstrate how the OECD and subsidiary bodies’ governance...
Mayday—Brexit
850–865
AbstractOn 31 January 2020, the United Kingdom left the European Union Brexit. A number of tax consequences both in the United Kingdom as well as in...
The Latin American Opposition to Mandatory Arbitration in Tax Treaties
Origins, the Calvo Doctrine, and a Reappraisal
866–884
AbstractThe international tax regime has recently made large strides toward a reform of its dispute resolution mechanism. Long-anticipated, mandatory...
Time for a U.S.–Brazil Tax Treaty
885–911
AbstractThe U.S. is the most relevant trade partner with whom Brazil does not have a tax treaty. Previous attempts to conclude it were not successful,...
Is Argentina Ready for the New International Tax Era?
912–945
AbstractWe are facing a new era in the international tax system. Even though we have achieved consensus in many areas, adopting multilateral solutions...
Main Tax Policy Matters for Establishing Chile as a Regional Operative Investment Hub
946–977
AbstractUnlike other OECD countries, Chile has not yet established a uniform tax policy toward foreign investment. Moreover, Chile had past experiences...
The War Triggered by a Ten Cents Tax on Natural Resources
978–1006
AbstractThis Article is intended to provide an historic tax analysis on the most controversial cause of the Pacific War (1879–1884) between Chile and...
Taxing Cross-Border Services
Two LATAM Experiences and a Couple of Conclusions for the (Developing) World
1007–1033
AbstractMany developing countries have been trying to expand in the last decades their taxing powers on cross-border services rendered by non-residents...
Taxpayers' Rights
Comparative Analysis of the United States of America and the Latin American Institute of Tax Law (ILADT)
1034–1054
AbstractThis Article addresses the challenges, trends, and evolution of Taxpayers’ Rights both in the Unites States and in Latin America, particularly...