Articles
Crisis-Driven Tax Law: The Case of Section 382
1-72
AbstractAt the peak of the 2008 financial crisis, the Internal Revenue Service (IRS) issued Notice 2008–83 (the Notice), administrative...
Revisiting Federal Tax Treatment of States, Political Subdivisions, and Their Affiliates
73-129
AbstractSeveral provisions of the 2017 tax legislation, known as the Tax Cuts and Jobs Act (TCJA), focused attention on federal taxation...
Stabilizing “Pillar One”: Corporate Profit Reallocation in an Uncertain Environment
130-192
AbstractThis Article is about how the world reestablishes international tax order.
The Article focuses on...
Can Anyone Be Trusted to Enforce National Treatment Disciplines With Respect to Tax Measures?
193-237
AbstractBecause the traditional non-discrimination article of tax treaties seemingly provides protection against only the most blatant...
Saving the Planet by Cutting Corporate Taxes: A Comparative Case Study Analysis
238-292
AbstractThis Article examines corporate tax trends in the context of the pressing global issue of climate change. Multinational...
Carbon Tax Shifts and the Revenue-Neutrality Dilemma
293–348
AbstractOver the past two decades, numerous experts and politicians have proposed “revenue-neutral carbon tax shifts,” under which a government...
Contribution and Distribution Flexibility and Tax Pass-Through Entities
349–431
AbstractThe way jurisdictions design their tax systems for business operations can be a contentious issue, as they try to balance the competing goals of...
Don't Blame It on WTO Law: An Analysis of the Alleged WTO Law Incompatibility of Destination-Based Taxes
432–493
AbstractThe idea that corporations should be taxed in the jurisdiction where they make their sales or provide their services is getting more and more...