Published: 2020-03-13

Crisis-Driven Tax Law: The Case of Section 382

Albert H. Choi, Quinn Curtis, Andrew T. Hayashi

1-72

Abstract

At the peak of the 2008 financial crisis, the Internal Revenue Service (IRS) issued Notice 2008–83 (the Notice), administrative...

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Revisiting Federal Tax Treatment of States, Political Subdivisions, and Their Affiliates

Ellen P. Aprill

73-129

Abstract

Several provisions of the 2017 tax legislation, known as the Tax Cuts and Jobs Act (TCJA), focused attention on federal taxation...

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Stabilizing “Pillar One”: Corporate Profit Reallocation in an Uncertain Environment

Itai Grinberg

130-192

Abstract

This Article is about how the world reestablishes international tax order.

The Article focuses on...

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Can Anyone Be Trusted to Enforce National Treatment Disciplines With Respect to Tax Measures?

Patricia A. Brown

193-237

Abstract

Because the traditional non-discrimination article of tax treaties seem­ingly provides protection against only the most blatant...

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Saving the Planet by Cutting Corporate Taxes: A Comparative Case Study Analysis

Roberta Mann, Fiona Martin, Bill Butcher

238-292

Abstract

This Article examines corporate tax trends in the context of the press­ing global issue of climate change. Multinational...

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Carbon Tax Shifts and the Revenue-Neutrality Dilemma

Rory Gillis

293–348

Abstract

Over the past two decades, numerous experts and politicians have proposed “revenue-neutral carbon tax shifts,” under which a government...

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Contribution and Distribution Flexibility and Tax Pass-Through Entities

Brett Freudenberg, Bradley T. Borden

349–431

Abstract

The way jurisdictions design their tax systems for business operations can be a contentious issue, as they try to balance the competing goals of...

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Don't Blame It on WTO Law: An Analysis of the Alleged WTO Law Incompatibility of Destination-Based Taxes

Alice Pirlot

432–493

Abstract

The idea that corporations should be taxed in the jurisdiction where they make their sales or provide their services is getting more and more...

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