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Reg. Section 1.482-7: A Wish List

20 Oct 2026

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Jeffery M. Kadet

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Papers & Reports
Reg. Section 1.482-7: A Wish List

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TAXING THE CREATOR ECONOMY: ASSESSING COMPLIANCE CHALLENGES, INFORMAL DIGITAL LABOR, AND CROSS-BORDER INCOME TAXATION OF SOCIAL MEDIA INFLUENCERS

29 Oct 2026

Multinational Responses to Coordinated Tax Reform: Evidence from the Global Minimum Tax

23 Oct 2026

A New View of Taxation

21 Oct 2026

Reg. Section 1.482-7: A Wish List

20 Oct 2026

The Side-by-Side Package of Pillar 2: It's "Simple"

28 Sep 2026

AI Token Budgets for Workers: Labor, Tax and Financial Treatment in Mexico

24 Sep 2026

Residence for Corporate Income Tax Purposes - General Report

21 Sep 2026

Examining The Minimum Effective Tax Rate and Controlled Foreign Company Rules: Assessing Nigeria’s Alignment with International Tax Standards

18 Sep 2026

Global Corporate Tax Governance: Crisis, Consensus, Revolution

15 Sep 2026

Restructuring International Service Taxation: Why is the New Article 12AA a Gamechanger for Developing Countries?

14 Sep 2026

Which Tax Incentives Survive Pillar Two? A Comparative Simulation of QDMTT Exposure Across Six Incentive Archetypes

11 Sep 2026

Tax Sovereignty and Investor Protection: Why the Proposed Global Minimum Tax Is Not the Final Frontier for Corporate Tax Arbitrage

11 Sep 2026

Reforming the Effectively Connected Income Rules to More Accurately Capture U.S. Business Income

10 Sep 2026

Who Concedes Their Tax Base? The Domestic Politics of Global Taxation

31 Aug 2026

Taxing Software Payments: Embedded Royalties and the Australian Taxation Office's Nonuniform Approach

31 Aug 2026

Does QDMTT Neutralize Section 10AA? A Simulation of Pillar Two, India SEZ and Belgium Holding

28 Aug 2026

Restructuring International Tax Regimes for Climate Justice: A Legal-Governance Framework for Climate-Compatible Taxation

28 Aug 2026

The Substance Trap Transfer Pricing and the Global Minimum Tax After the 2026 Side by Side Package: Long Run Consequences for West Africa and for Nigeria

28 Aug 2026

Jurisdictional Assignment Functions: Comparing Competing Situs Rules in the Taxation of Digital Assets

27 Aug 2026

Refunding the IEEPA Tariffs

22 Aug 2026

Whose Rate Is It? Licensor Identity and the Limits of Comparability Analysis in Royalty Pricing: Evidence from 6,050 Disclosed Licences in Seven Jurisdictions

21 Aug 2026

Proposed Amendments to the Co-Lead's Draft Protocol on the Taxation of Income from Cross-border Services, A/AC.298/CRP.33

20 Aug 2026

Cultural and Creative Tax Incentives -A Cross-Border Legal and Regulatory Framework

19 Aug 2026

Source Sovereignty: A Continental Framework for Taxing Value Where It Is Created in Africa

16 Aug 2026

Will Pillar Two Prosper Despite the US Side-by-Side Arrangement? A Doctrinal and Structural Analysis: Institutional Adjustment and the Emerging Fragmentation of Global Tax Governance

13 Aug 2026

How Do U.S. Multinationals Navigate the Global Minimum Tax?

11 Aug 2026

UNFCITC Protocol on the Taxation of Cross-Border Services: A Primer of the Fifth Session Zero-Draft

06 Aug 2026

The U.S. Tax Paradox

05 Aug 2026

Presidential Power over Wartime and Secondary Tariffs

05 Aug 2026

Does the Place of Effective Management (POEM) Test Survive BEPS 2.0? Rethinking Corporate Residence in the Era of Global Minimum Tax

04 Aug 2026

Taxing Cross-Border Services

31 Jul 2026

Tax Competitiveness and Business R&D Expenditures: Do Taxes Matter for Innovation?

29 Jul 2026

Withdrawing Tax Incentives and Pillar II: Micula Versus Romania Reconsidered

29 Jul 2026

Pigou Goes Abroad

28 Jul 2026

When Do Accountants Matter? Evidence from Random Allocation of Tax Experts

27 Jul 2026

From Aiken to AI: Evolution and Innovation in Combatting Treaty Shopping and Tax Avoidance in International Tax Law

24 Jul 2026

Bridging the Gap Between International Taxation and Development: Are There Feasible Alternatives to the Arm’s Length Standard?

23 Jul 2026

BEPS Action 5: Jurisdictions make further progress in addressing harmful tax practices under new review methodology

23 Jul 2026

Impact of the Global Minimum Tax on Domestic Tax Legislation

22 Jul 2026

The Determinants of the EU Tax Haven List

21 Jul 2026

Hong Kong's Strategic Tax Policies for Innovation and R&D: Navigating Regional Competition and Global Minimum Tax Compliance

20 Jul 2026

Balancing Acts: Tariffs, Proportionality, and the EAC Common Market

20 Jul 2026

Reimagining Fiscal Sovereignty: Digitalization And the Emerging Legal Frontiers of Tax Administration in Nigeria

20 Jul 2026

Taxation and Deglobalization

16 Jul 2026

Challenges of Taxing Business Profits Arising from Digital Transactions in Rwandan Law: A Critical Analysis of the Legal Framework and the Way Forward

16 Jul 2026

MNE Responses to the Global Minimum Tax

15 Jul 2026

Measuring Location-Specific Rents

15 Jul 2026

From "Reporting" to "Rule-of-Law": Digital Governance as a Defensive Shield Against Administrative Discretion in Emerging Markets

14 Jul 2026

Jane Street Capital's Indian Tax Battle Begins

10 Jul 2026

The Paradox of Reporting Without Visibility: How DAC8 And CARF Expose the Limits of Transparency-Based Taxation in Crypto-Assets

10 Jul 2026

U.S. Tax Reform and International Trade

10 Jul 2026

Tax Inspectors Without Borders Annual Report 2026

02 Jul 2026

30 Years of Research on Income Shifting—Review and Looking Ahead

30 Jun 2026

Statutory Measures Adopted by Pakistan to Tax Cross-Border Digital Transactions: Inconsistencies and Inadequacies?

29 Jun 2026

Crypto Taxation: Challenges in Defining and Regulating Digital Assets in the EU and Beyond

25 Jun 2026

Who Taxes Your Salary When You Work From Home? International Tax Treaties and Cross-Border Telework

25 Jun 2026

Who Bears the Burden of Digital Services Taxes?

24 Jun 2026

Fundamentals of Indirect Taxation

24 Jun 2026

Navigating the Amazon: The Incidence of Digital Service Taxes

12 Jun 2026

Shrinking Tax Sovereignty In Canada? Evidence from the Income Tax Act

10 Jun 2026

Retaliatory Taxation and the Birth of America's First Tax Treaty

10 Jun 2026

Global Tax for Repair

03 Jun 2026

Notice 2026-23, 2026-2027 Priority Guidance Plan

26 May 2026

Trade Agreements and Domestic Policy under Variable Markups

03 May 2026

References to Dynamic International Standards and the Tax Legality Principle

02 May 2026

MNE Roadkill? Why Pillar 2 Survives With or Without the U.S.

26 Apr 2026

The Role of Residence-Based Taxation in Business Income Taxation

25 Apr 2026

US-China Cooperative Interdependence: Opportunities and Obstacles

25 Apr 2026

Arthur Cockfield's Digital Economy: A Retrospective Analysis

24 Apr 2026

Taxing Data as the New Oil

20 Apr 2026

Can Sales Destinations Reclaim Taxing Rights on Profits from Cross-Border Sales of Goods on Digital Platforms?

15 Apr 2026

The Largest Tax Fraud?

13 Apr 2026

International Taxation and the Frustrations of Formulary Apportionment Estimation

10 Apr 2026

The Awkward Implications of an Undertaxed Profits Rule

09 Apr 2026

Should I Stay or Should I Go? The Impact of Taxation on Canadian Inter-Provincial Migration

09 Apr 2026

Quantifying Climate Damages When Regions Trade: A Structural Gravity Approach

09 Apr 2026

Corporate Taxation And Data Centers

06 Apr 2026

Impact of Environmental Measures on International Trade (with focus on EU CBAM & WTO law)

03 Apr 2026

Carbon Taxes and ESG Compensation

03 Apr 2026

Dynamic Adjustment to Trade Shocks

31 Mar 2026

Tax Compliance Costs of Pillar Two – A Qualitative Study

30 Mar 2026

Tax Compliance Costs of Pillar Two - A Qualitative Study

30 Mar 2026

OECD Pillar Two and U.S. GILTI: Comparative Analysis and Policy Implications for Multinational Tax Compliance

20 Mar 2026

The Sovereignty Paradox: Digital Services Taxes, Political Jurisprudence and the Limits of State Power in the Digital Economy

19 Mar 2026

How the U.S. Constitution Shapes International Tax Law: Instrument Choice in Tax Agreements

17 Mar 2026

Digital Services Taxes and the WTO

16 Mar 2026

International Tax Reform and Multinational Corporate Behavior: Conceptual Insights from the One Big Beautiful Bill Act

07 Mar 2026

Fiscal Limits to Protectionism: The 2025 U.S. Tariff Laffer Curve

06 Mar 2026

Hidden Profits, Lost Jobs? Tax Havens and Employment Decisions

05 Mar 2026

What is the Share of U.S. Tariffs Paid by Exporters?

04 Mar 2026

The “Hidden Sides” of the Taxation of Dividends and Interest for Corporate America versus Corporate Europe

04 Mar 2026

Tariffs and Firm Expectations

02 Mar 2026

From Physical Presence to Digital Participation Toward a Participation-Based Nexus Doctrine in State Taxation

21 Feb 2026

Options for a Protocol on Services under the UN Framework Convention on International Tax Cooperation

13 Feb 2026

Tax Incentives for Nigerian Oil and Gas Companies under the Nigeria Tax Act

10 Feb 2026

The Controlled U.S. Corporate Footprint by Owner Jurisdiction: Evidence from IRS SOI Data (2002–2022)

04 Feb 2026

Uneven State-Level Exposure to Potential U.S. Tariff Disputes with Canada and Mexico

04 Feb 2026

A Leak in Paradise: Reputation Repair Policies After Offshore Data Leaks

04 Feb 2026

The Definition and Application of the Separate-Entity Approach in the OECD Transfer-Pricing Guidelines

28 Jan 2026

Australian Tax Treaty Policy: The Dilemma of a Wealthy Capital-Importing Nation

15 Jan 2026

Income Shifting from Transfer Pricing: Further Evidence from Tax Return Data by

14 Jan 2026

The Pillar Two Regime in the Post-Implementation Era: Structural Mechanics and Geopolitical Fragmentation (2026)

13 Jan 2026

Withholding Taxes in Developing Countries: Relief Method and Tax Sparing in Tax Treaties with OECD Members

07 Jan 2026

Taxing Mobile Money: Theory and Evidence

16 Dec 2025

Pillar Two Side-by-Side Challenges of EU Law, Global Tax Governance, Sovereignty. Comments for a Rational Win-Win Path Forward

09 Dec 2025

Taxing One Side Hurts the Other: DSTs, BEPS, and Platform Competition

03 Dec 2025

Trade Policy Uncertainty and Supply Chain Disruptions: Firm-Level Evidence from "Liberation Day"

25 Nov 2025

Taxing Automation: The Fourth Industrial Revolution in Extractive Industries

21 Nov 2025

Why EU Revenue Matters: A Case for an EU Digital Levy

21 Nov 2025

To Tariff or Not to Tariff? That is the Question (before the U.S. Supreme Court)

17 Nov 2025

Beyond Economic Allegiance

04 Nov 2025

Effects of the Global Minimum Tax on German Corporations

03 Nov 2025

A Tax in Form, a Tariff in Function: Reclassifying Digital Services Taxes to Restore Trade Law Coherence

03 Nov 2025

Catching Pokémon, Not Tax Bills

31 Oct 2025

The Rise of Refinery Margins: The Case of the Energy Tax Cut in Germany

29 Oct 2025

The Origination Clause And The President's Tariffs

22 Oct 2025

IFA Central Report: Improper Use of Tax Treaties and Source Taxation: Policy, Practice and Beyond

21 Oct 2025

Taxing AI Across Borders: The Benefits of In-Kind Remittance for Cross-Border Taxation

17 Oct 2025

Economic Fragmentation And The Future Of International Tax Cooperation

14 Oct 2025

Tariffs as Fiscal Policy

26 Sep 2025

The Global Minimum Tax and The Future of International Taxation

17 Sep 2025

Transparency, Trust, Transnationality, and Tax Compliance: Lessons from Google's Financial Reporting Practices in New Zealand

11 Sep 2025

Comprehensive Analysis of Tariff Effects on the United States Economy

09 Sep 2025

The Effect of Third-Country Tariffs on Bilateral Trade

06 Sep 2025

Real Effects of Earnings Stripping Rules

03 Sep 2025

No Trade Wars Without Taxation -Who's to Blame, and What Comes Next?

29 Aug 2025

The Home Office as a Permanent Establishment: Legal and Practical Considerations

28 Aug 2025

The Boomerang Tariffs Effect on the U.S. Economy

12 Aug 2025

Crypto in the Shadows: Why Global Tax Systems Struggle to Regulate Digital Asset Conversions

12 Aug 2025

Allocative Justice as a Constraint on Fiscal Imperialism in International Tax

04 Aug 2025

"Reciprocal" Tariffs: What are They Really For?

04 Aug 2025

The 2025 update of the UN Model Tax Convention

30 Jul 2025

What Went Wrong in the Apple State Aid Case and How to Fix It - Part 2: Suggested Reforms

29 Jul 2025

Assessing the Influence of Artificial Intelligence on Corporate Tax Compliance and Financial Reporting

24 Jul 2025

Recent Developments in the Taxation of Cross-Border Services: LATAM Position(s) on the UN Terms of Reference (ToR)

22 Jul 2025

Rule of Law v. Rule of Power: US Tax Defense Measures in Light of the International Law of Countermeasures

09 Jul 2025

Tariff Evasion During the 2018–2019 Us-China Trade War: Evidence from Missing Imports in the United States

05 Jul 2025

The 2025 U.S.-China Trade War: Investors' Response to Trade Policy Escalation

01 Jul 2025

Impact Of the Un Zero Draft Terms of Reference on Global Tax Policymakingcross-border services

20 Jun 2025

Reforming the Foreign Tax Credit, Subpart F, and GILTI in Light of Pillar Two

19 Jun 2025

From Profits to Paperwork: Multinationals and the Cost of Transfer Pricing Regulation

13 Jun 2025

Specific Taxation Points in the Digital Economy: First the Issues, then the Solutions

10 Jun 2025

Are Businesses Absorbing the Tariffs or Passing Them on to Their Customers?

09 Jun 2025

The Propagation of Tariff Shocks via Production Networks

04 Jun 2025

What Went Wrong in the Apple State Aid Case: Part 1 - The Case

03 Jun 2025

The Forgotten Attribution Power

29 May 2025

Income Source in a Digital Age

28 May 2025

Preferential Liberalization and MFN Tariffs: New Evidence from a Global Sample of Free Trade Agreements

28 May 2025

The Global Minimum Tax and Intra Western Tax Competition

23 May 2025

Trump Tariffs and Stock Prices

19 May 2025

The Impact of the US-China Trade War on Vietnam's Us Exports

16 May 2025

Crystals and Mud in International Taxation: Why the Principal Purpose Test's Impact Will Not Meet Expectations

15 May 2025

Transfer Pricing and Investment - How OECD Transfer Pricing Rules Affect Investment Decisions

15 May 2025

Weaponization of Trade Measures and Countermeasures

09 May 2025

Capital and Income Allocation in International Tax Planning and the Coordination of Joint Innovations among Subsidiaries of MNCs

06 May 2025

Modernising the Permanent Establishment Concept: Evaluating Its Relevance in a Changing Business Environment and the Sufficiency of Recent Amendments

06 May 2025

Making America Great Again? The Economic Impacts of Liberation Day Tariffs

03 May 2025

Canada at Trade War

02 May 2025

Tariff Pass-Through in the Trade War: A Firm-Heterogeneity Perspective

02 May 2025

The US-China Trade War Creates Jobs (Elsewhere)

30 Apr 2025

Destined for Division? US and EU Responses to the Challenge of Chinese Overcapacity

29 Apr 2025

The US Revenue Implications of President Trump's 2025 Tariffs

29 Apr 2025

Killing the WTO

24 Apr 2025

Global Tax Decluttering

21 Apr 2025

The Normative Shift in Corporate Tax Policy after GloBE

14 Apr 2025

Negative Spillovers in International Corporate Taxation and the European Union

11 Apr 2025

Unequal Inflationary Effects of Tariffs across Socio-Demographic Groups

11 Apr 2025

The Hole in the Global Minimum Tax

04 Apr 2025

The America First Trade Policy: The Knowable and Unknowable Consequences

01 Apr 2025

Weaponization of Taxation: Sovereign Tax Immunity as a National Security Tool

28 Mar 2025

EU State Aid and the Tax Allocation of Multinationals' Profits

25 Mar 2025

How Canada Should Respond to the Trump Tariff

21 Mar 2025

Was The NIIT A Treaty Override?

18 Mar 2025

The Economic Consequences of A Three-front Trade-War

10 Mar 2025

Economic Costs of Geo-Economic Fragmentation: Scenarios of Friend-Shoring Based on GVC

10 Mar 2025

Tariff, Wages and Compensation: A General Oligopolistic Equilibrium Analysis

07 Mar 2025

Retaliatory Taxation

04 Mar 2025

MANDATORY BINDING TAX TREATY ARBITRATION IN THE POST-BEPS WORLD: A GOOD OPTION FOR AFRICAN COUNTRIES?

03 Mar 2025

Sanction Busting via Industry Boosting: How China Strategically Counteracts US Sanctions on Chinese Firms

03 Mar 2025

The use (and misuse) of tariffs in North America: A new trade war?

24 Feb 2025

Breaking down the CJEU’s decision in Apple: An unsatisfactory outcome

21 Feb 2025

A Better Tool to Counter China's Unfair Trade Practices

20 Feb 2025

Is the US Exit Tax Constitutional?

18 Feb 2025

The Us Dollar and the Effectiveness of Us Trade Policy

14 Feb 2025

Evolving Networks: Information Exchange's Reshaping of Global Finance

10 Feb 2025

Does Anti-Tax Avoidance Regulation Curb Industry Concentration?

07 Feb 2025

Trade Policy Uncertainty and Inflation Tax Dynamics: Is the 'Most Beautiful Word' a Tax in Disguise?

03 Feb 2025

Amount B comes to the United States

31 Jan 2025

Developing Countries, Tax Treaty Shopping and the Global Minimum Tax

29 Jan 2025

Anticipating Trade Turbulence: Assessing the Economic Impacts of President Trump’s Proposed Tariff Scenarios

28 Jan 2025

Navigating Tariff Risks: Stockpiling, Sourcing Diversification, or Responsive Pricing?

27 Jan 2025

BRIEFING PAPER: TOWARDS A PROTOCOL ON TAXING CROSS-BORDER SERVICES

25 Jan 2025

TAXING CORPORATE PAYOUTS

21 Jan 2025

The Interaction Between the UTPR and Tax Treaties: Selected Issues

09 Jan 2025

Substantive Tax Sovereignty Under Globalization

07 Jan 2025

Sustainable tax governance: a shared responsibility

06 Jan 2025

International Tax Reform: Release of New Tools for the Implementation of Amount B Relating to the Simplification of Transfer Pricing Rules

19 Dec 2024

Harmful Tax Practices – 2023 Peer Review Reports on the Exchange of Information on Tax Rulings

16 Dec 2024

Dos the U.S. Have to be a Tax Haven?

12 Dec 2024

The Unintended Consequences of Global Tax Asymmetries on Foreign Risk-Taking

19 Nov 2024

2023 Mutual Agreement Procedure Statistics

15 Nov 2024

Whither The Un Framework Convention?

11 Nov 2024

On Pillar Two controversy and trust

07 Nov 2024

The OECD's Work on Profit Allocation and Nexus Rules for a Digitalized Economy: A Potential Improvement of the International Taxation Framework?

04 Nov 2024

Cloud Computing: Difficulties in Applying Current and Proposed Nexus and Profit Allocation Rules in a Cross-Border Scenario

04 Nov 2024

Value Creation: A Guiding Light for the Interpretation of Tax Treaties?

04 Nov 2024

Remarks on the Future Prospects of the OECD/G20 Programme of Work: Profit Allocation (Pillar One) and Minimum Taxation (Pillar Two)

04 Nov 2024

A Multilateral Interpretation of the Multilateral Instrument (and Covered Tax Agreements)?

04 Nov 2024

A New Pillar to Address Tax Challenges Arising from Digitalization of the Economy: Consensus-Based Digital Services Taxes?

04 Nov 2024

Taxation of Income from Cross-Border Services: A Global Normative and Enforcement Approach to Legal Issues and Policy Options

31 Oct 2024

The True Nature of Tax Treaties

29 Oct 2024

International Tax Implications for Private Equity Investments

29 Oct 2024

Measuring Tax Burden Efficiency in OECD Countries: An International Comparison

28 Oct 2024

Reimagining Global Tax Governance: A Two-sided Platform Perspective

28 Oct 2024

Proposal for a Council Directive Amending Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation

28 Oct 2024

OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (G20 Brazil, October 2024)

24 Oct 2024

Capital Flows and Wealth Distribution in a Global Economy with Asymmetric Countries

23 Oct 2024

Update on the Revenue Effects of GILTI and FDII, 2026 Rate Changes, and Proposed Policy Reforms

15 Oct 2024

The Implications of Treaty Restrictions of Taxing Rights on Services, Especially for Developing Countries

14 Oct 2024

10 Years of Banking Union’s Case-Law: How Did European Courts Shape Supervision and Resolution Practice in the Banking Union?

03 Oct 2024

Tax Policy Reforms 2024: OECD and Selected Partner Economies

30 Sep 2024

Digital Economy & Taxation: Challenges and Opportunities In Nigeria

27 Sep 2024

Comment Letter on the June 2024 Administrative Guidance

26 Sep 2024

Corporate Inversions and the Global Ultimate Owner: Challenges in International Business Research

18 Sep 2024

How Kamala Harris's Tax Hike Could Affect Business Growth

18 Sep 2024

Country-by-Country Reporting – Compilation of 2024 Peer Review Reports

16 Sep 2024

The EU's Uncoordinated Approach to Tax Avoidance and Tax Abuse in Relation to 'Uncooperative' Tax Jurisdictions

16 Sep 2024

Reimagining Tax Treaty Dispute Resolution; beyond MAP and Arbitration

13 Sep 2024

Cross-Border Taxation in a World of Abundant Capital

12 Sep 2024

International Compliance Assurance Programme (ICAP) Outcome Letter Template

11 Sep 2024

The Future of European Competitiveness – A Competitiveness Strategy for Europe

09 Sep 2024

The Subject to Tax Rule: A Comparison of The OECD and UN Versions

03 Sep 2024

Tokenization: Unlocking Developing Countries Wealth

03 Sep 2024

FTC Proposals, Part II: TCJA White Paper

27 Aug 2024

An Investigation of the Array of Domestic and Foreign Tax Haven Location Decisions for U.S. Multinational Firms

26 Aug 2024

Why the U.N. Must Put AI and Data on the Tax Agenda

26 Aug 2024

International Tax Scholarship and International Tax Activism

22 Aug 2024

FTC Proposals, Part I: Creditable Foreign Taxes

20 Aug 2024

Climate Policies and External Adjustment

19 Aug 2024

A New Governance Framework in Cross-Border Tax Policymaking

19 Aug 2024

Chair’s Proposal for Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

15 Aug 2024

Taxation of the Digital Economy: An Appraisal of the Effectiveness of the OECD Tax Deal on Low-and-Middle Income Countries

14 Aug 2024

Globalization, Erosion of Tax Base, and the Revenue Potential of Developing Asia's Foreign Exchange Reserve Build-Up

13 Aug 2024

Potential Changes to Section 367 and the Associated Treasury Regulations

07 Aug 2024

A Global Perspective on the Incidence of Monopoly Distortions

05 Aug 2024

International Tax Reform and the Biden-Harris Tax Pledge

05 Aug 2024

Subpart F and GILTI Recommendations

31 Jul 2024

Taxation of Foreign-Derived Intangible Income

30 Jul 2024

Power and Expertise in Global Tax Governance

30 Jul 2024

India’s Pillar Two Pledge May Have Limited Impact, Experts Warn.

30 Jul 2024

U.S. Ownership of Foreign Stock: Dividends and Gains on Sale

24 Jul 2024

U.S. Subsidiaries of Foreign-Based MNEs — BEAT and Section 163

23 Jul 2024

Interpreting Tax Treaties: The Importance of Post-Treaty Commentary to the OECD Model Tax Convention for Achieving Uniformity and Ensuring the Success of the New International Tax Order

22 Jul 2024

Mulilateral Tax Reform

22 Jul 2024

The Taxation of Robots and Its Global Challenges

22 Jul 2024

Revised Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

19 Jul 2024

ICAP Documentation Requirements: Selection Documentation Package Templates

18 Jul 2024

The EU as a Tax Harmonisation Catalyser – Triumphs and Challenges within an Asymmetric Cooperation Model

17 Jul 2024

Considerations Relating to CFC Stock Ownership and Allocation of Subpart F Income

17 Jul 2024

Considerations for Reforming the U.S. Source of Income Rules

16 Jul 2024

The Global Minimum Tax and Special Economic Zones

16 Jul 2024

International Tax and International Law Revisited

11 Jul 2024

Can Investment Treaties Defeat Pillar 2

11 Jul 2024

Corporate Tax Statistics

11 Jul 2024

Principles Justifying the Reallocation of Taxing Rights to Market Jurisdictions: Do We Need Them?

11 Jul 2024

Considerations for Reforming the U.S. Transfer Pricing Rules

09 Jul 2024

Qualified Status under the Global Minimum Tax: Questions and Answers

17 Jun 2024

Tax Challenges Arising from the Digitalisation of the Economy –Administrative Guidance on the Global AntiBase Erosion Model Rules (Pillar Two), June 2024

17 Jun 2024

Broadening the Gains from Generative AI: The Role of Fiscal Policies

17 Jun 2024

A Toss Up? Comparing Tax Revenues from the Amount A and Digital Service Tax Regimes for Developing Countries

10 Jun 2024

Zero Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

07 Jun 2024

International Compliance Assurance Programme (ICAP) Frequently Asked Questions

04 Jun 2024

A Scrap Game: Impacts of the EU Carbon Border Adjustment Mechanism

03 Jun 2024

2024 Progress Report on Tax Co-operation for the 21st Century

24 May 2024

Taxation and the Realisation of Socioeconomic Rights in Africa: What Is the Role of International Cooperation?

15 May 2024

The Role of the Investor Motive in the Effectiveness of Tax Incentives: Evidence for FDI Location in Indonesia

13 May 2024

Tax Hybridity and the Globalization of Taxation: Convergence, Borrowing, Culture

01 May 2024

A Global Minimum Tax for Large Firms Only: Implications for Tax Competition

26 Apr 2024

Detecting Cross-Border Transaction Patterns Using Machine Learning: The Case of Indonesia

25 Apr 2024

Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023)

25 Apr 2024

Profit-Shifting Elasticities, Channels, and the Role of Tax Havens: Evidence from Micro-Level Data

22 Apr 2024

Import Competition and U.S. Sentiment Toward China

22 Apr 2024

The Design of a UN Framework Convention on International Tax Cooperation

22 Apr 2024

Taxation of Autonomous Artificial Intelligence: Socially Sustainable Expansion of Automation and Impacts on International Tax

15 Apr 2024

Tax Treaties and Denizenship Based Tax Systems

11 Apr 2024

Design and Consequences of CFC and GILTI Rules: A Review and Potential Lessons for the Global Minimum Tax

04 Apr 2024

Tax Treaties and Income Shifting

04 Apr 2024

The OECD/G20 Pillar 1 and Digital Services Taxes: A Comparison

01 Apr 2024

The Digital Economy, Global Tax Reforms and Developing Countries – An Evaluation of Pillar I and Art. 12B UN Model

28 Mar 2024

Broader Border Taxes: A New Option for European Union Budget Resources

21 Mar 2024

Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax

20 Mar 2024

Promoting Inclusive and Effective Tax Cooperation at the United Nations

16 Mar 2024

Case Law Trend: Withholding Taxation Under the Fundamental Freedoms

14 Mar 2024

Location, Financial and Real Effects of CFC Rules after the ATAD Implementation in the EU

09 Mar 2024

Tax Transparency in Africa 2024: Africa Initiative Progress Report

06 Mar 2024

2024 European Elections Manifesto: The Accountancy Profession’s Priorities for the EU Mandate 2024 - 2029

05 Mar 2024

Background and Analysis of the Taxation of Multinational Enterprises and the Potential Reallocation of Taxing Rights Under the OECD’s Pillar One

05 Mar 2024

Business model digitalization, competition, and tax savings

01 Mar 2024

International Cooperation on Tax Matters at the United Nations: A Turning Point in History?

01 Mar 2024

Understanding the Impact of OECD BEPS Actions on Double Tax Treaties

29 Feb 2024

The Untold Tale of a Tax Rulings Haven

29 Feb 2024

Exchange of Information, Tax Confidentiality, Privacy and Data Protection from an EU Perspective

28 Feb 2024

Analysis of Developments in EU Capital Flows in the Global Context (2023)

28 Feb 2024

Pillar One - Amount B

19 Feb 2024

Cryptocurrency Investments and Taxation: Analyzing Global Responses by Tax Authorities

18 Feb 2024

The Proposal for a Council Directive on Transfer Pricing: An Assessment

13 Feb 2024

Deterrence and Displacement in Offshore Trade: Evidence from the Panama Papers Leak

13 Feb 2024

The consequences of the 2017 US international tax reform: a survey of the evidence

03 Feb 2024

Whither LOB?

02 Feb 2024

Dual-residency of Companies and EU Law: Accessing Corporate Tax Directives’ Benefits After the 2017 OECD Model Tax Convention Changes in the Dual-residency Tie-breaker for Companies

30 Jan 2024

Tax It Before Exit: Exit Taxation and Greenfield Investments

26 Jan 2024

The UTPR and the Treaties

10 Jan 2024

The Tax Attractiveness of EU Locations for corporate Investments: A Stocktaking of past Developments and recent Reforms

10 Jan 2024

Corporate income tax, IP boxes and the location of R&D

10 Jan 2024

The Global Minimum Tax and the taxation of MNE profit

09 Jan 2024

Taxing Digital Platforms

03 Jan 2024

Frequently Asked Questions on Pillar 2 Directive

26 Dec 2023

Are Consumers Paying the Bill? How International Tax Competition Affects Consumption Taxation

23 Dec 2023

Macroeconomic Policy Questions: Promotion of Inclusive and Effective International Cooperation on Tax Matters at the United Nations

22 Dec 2023

Financial Constraints and Tax Planning: International Evidence

20 Dec 2023

Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), December 2023

18 Dec 2023

Destination Taxation of Corporate Income and the Emerging Implications

05 Dec 2023

Tax In History: CFCs and Tax Treaties: Historical Elements for the IIR Debate

30 Nov 2023

Directions for International Tax Policy, A Response to Hanna and Wilson

29 Nov 2023

Corporate Tax System Complexity and Investment

27 Nov 2023

Effective tax rates of MNEs: New evidence on global low-taxed profit

21 Nov 2023

Corporate Tax Statistics 2023

21 Nov 2023

International Tax Policy's Harm to Manufacturing and National Interests

01 Nov 2023

Country-by-Country Disclosures and Firms' Internal Information Environment

01 Nov 2023

Pillar 2: QDMTT or Safe Harbour Domestic Minimum Top-Up Tax (SHDMTT)?

31 Oct 2023

‘Just BEAT It’ Do Firms Reclassify Costs to Avoid the Base Erosion and Anti-abuse Tax (BEAT) of the TCJA?

31 Oct 2023

Global Tax Evasion Report 2024

23 Oct 2023

Profit Shifting Under the Arm’s Length Principle

19 Oct 2023

The Historical Origins and Current Prospects of the Multilateral Tax Convention

12 Oct 2023

A New Scenario in International Tax Law: Two Proposals to Rethink the OECD Model in Response to the Generalization of Distance Work by Employees

12 Oct 2023

Minimum Tax Implementation Handbook (Pillar Two)

11 Oct 2023

The Multilateral Convention to Implement Amount A of Pillar One

11 Oct 2023

Explanatory Statement to the Multilateral Convention to Implement Amount A of Pillar One

11 Oct 2023

Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule

03 Oct 2023

Simplified Application of the Arm’s Length Principle for Baseline Distribution Functions offers win/win for MNEs and Tax Authorities - A Risk Management Perspective on the OECD Amount B Proposal

02 Oct 2023

Government Reputation, FDI, and Profit-shifting

02 Oct 2023

Mutual Agreement Procedure and Foreign Direct Investments: Evidence from Firm-level Data

02 Oct 2023

Tax Arbitration and Foreign Direct Investments: A comparison between developed and developing countries

02 Oct 2023

The Effect of U.S. Tax Reform on U.S. R&D-Intensive Multinational Companies

26 Sep 2023

Enigma of the United States, Base Erosion, and the Global Minimum Tax

01 Sep 2023

Globe: The Potential Costs Of Cooperation

28 Aug 2023

Targeted Measures Against Intra-Group Debt Financing: What Needs and Design Options in Light of the ATAD, Transfer Pricing Rules, and Pillar 2?

28 Aug 2023

UN MTC Article 14: The Mistaken Retention

28 Aug 2023

Global Tax Hubs

28 Aug 2023

Strategic Narratives in International Tax Policy Making: Beps Action 1 and the Stability Argument

22 Aug 2023

Can the OECD Author an Equitable International Tax Architecture?

22 Aug 2023

Transfer Price Documentation Rules and Multinational Firm Behavior - Evidence from France

22 Aug 2023

A Macroeconomic Perspective on Taxing Multinational Enterprises

15 Aug 2023

The Fundamentals of Tax Incentives

08 Aug 2023

Promotion of inclusive and effective international tax cooperation at the United Nations

26 Jul 2023

The Use and Abuse of Location-Specific Rent

25 Jul 2023

Progressive Formulary Apportionment: The Case for 'Amount D'

25 Jul 2023

Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)

17 Jul 2023

The Influence of Macroeconomic Growth Opportunities on U.S. Effective Tax Rates on Foreign Earnings

17 Jul 2023

Pillar 2 and the Credits

10 Jul 2023

The Legitimacy Of The OECD’s Work On Pillar Two: An Analysis Of The Overconfidence In A ‘Devilish Logic’

10 Jul 2023

Tax Strategy Disclosure: A Greenwashing Mandate?

10 Jul 2023

The Effect of the Closure of the Double Irish Arrangement on the Location of U.S. Multinational Companies’ Profits

10 Jul 2023

Response to the UN Resolution A/RES/77/244 on Promotion of Inclusive and Effective Tax Cooperation at the United Nations

19 Jun 2023

Pillar I: The Marketing and Distribution Safe Harbour (MDSH) as Applicable to Licensed Manufacturers and Centralized Business Models: Does It Fulfill Its Policy Objective?

19 Jun 2023

Pillar 2 and the Bits

15 Jun 2023

Nothing New Under the Sun? The Historical Origins of the Benefits Principle

07 Jun 2023

Unitary Taxation After Pillar One

25 May 2023

Tax Implications of Contributing Appreciated Property Overseas

22 May 2023

Mandatory Binding Dispute Resolution in the Base Erosion and Profit Shifting (BEPS) Two Pillar Solution

22 May 2023

Implementing Pillar Two: Potential Conflicts with Investment Treaties

22 May 2023

Challenges at the intersection between investment provisions in regional trade agreements and implementation of the GloBE Rules under Pillar Two

20 May 2023

Intellectual Property and Tax Incentives: a Comparative Analysis of the EU and the US Legal Frameworks

20 May 2023

The Mirage of Mobile Capital

19 May 2023

Differing Abuse Concepts in Double Tax Conventions: At What Level and to What Extent Can Equality Be Realized?

19 May 2023

Who Really Matters in Corporate Tax?

19 May 2023

The Irish Apple Tax Disaster

19 Apr 2023

A Global Climate Wealth Tax to Fund a Worldwide, Just Transition

19 Apr 2023

The Global Corporate Minimum Tax: A Cure or Not?

03 Apr 2023

Public Finance in the Real World: Through the Lens (Down the Rabbit Hole?) of Transfer Pricing

03 Apr 2023

U.S. International Tax Policy and Corporate America

27 Mar 2023

Limits to Competition: Strategies for Promoting Jurisdictional Cooperation

27 Mar 2023

Global Profit Shifting of Multinational Companies: Evidence from CbCR Micro Data

27 Mar 2023

Tax Policy, Investment and Profit-Shifting

27 Mar 2023

Taxing Intellectual Property Assets on a Cross-Border Transaction: Application of Mobilia Sequuntur Personam and the Case of the India–Mauritius Tax Treaty

27 Mar 2023

Taxation of Information and the Data Revolution

27 Mar 2023

Taxing Multinationals: Three Lenses on International Tax Cooperation (Comments on UN Resolution 77/244, Promotion of Inclusive and Effective International Tax Governance at the United Nations)

27 Mar 2023

Taxing Zero

27 Mar 2023

Testimony for the Hearing “Cross-border Rx: Pharmaceutical Manufacturers and U.S. International Tax Policy”

27 Mar 2023

Optimal Taxation of Multinational Enterprises: A Ramsey Approach

27 Mar 2023

Crossing the Atlantic: The role of U.S. executives in tax planning of foreign subsidiaries

27 Mar 2023

Never-Ending Battle Between Privacy and Transparency: The Case of Registers of Beneficial Ownership Before the CJEU

27 Mar 2023

Why 15%? Justifying the Global Corporate Minimum Tax

27 Mar 2023

The Canadian Digital Services Tax

22 Mar 2023

The Physical, Human Driven Digital Economy: The Overvaluation of Intangibles and its Effects on Tax and Society

20 Mar 2023

The Effects of the Tax Cuts and Jobs Act on the Tax-Competitiveness of Multinational Corporations

20 Mar 2023

Designing Domestic Minimum Taxes in Response to the Global Minimum Tax

20 Mar 2023

The Retained EU Law (Revocation and Reform) Bill - Could the UK VAT System Operate Without EU Law?

20 Mar 2023

General Explanations of the Administration's Fiscal Year 2024 Revenue Proposals

14 Mar 2023

Trade Enforcement Tools and International Taxation: A Digital Services Tax Case Study

13 Mar 2023

Foreign Holding Companies and the US Taxation of Foreign Earnings: Evidence from TIPRA 2005

13 Mar 2023

The effect of US tax reform on the taxation of US firms’ domestic and foreign earnings

13 Mar 2023

An Indonesian Perspective on Global Tax Reform and Pillar 2

13 Mar 2023

Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)

08 Mar 2023

Education

Impact of Tax on Foreign Direct Investment

04 May 2017

Coordination of Transfer Prices on Intra-Firm Trade

04 May 2017

The Effect of IP Box Regimes on International IP Payments and Foreign Research and Development

30 Aug 2016

Cross-Country Evidence on the Preliminary Effects of Patent Box Regimes on Patent Activity and Ownership

01 Oct 2015

Corporate Inversions and Economic Performance

08 Sep 2015

ITPF Competitiveness Index 2015

17 Mar 2015

2014 ITPF Competitiveness Index_20140224b

25 Feb 2014

1995-2011 List of Research Papers

19 Feb 2014

Offshoring high-skilled jobs: EU multinationals and domestice employment of inventors

19 Feb 2014

The Intertemporal Substitution and Income Effects of GST Rate Increases: Evidence from New Zealand

19 Feb 2014

What Do We Know About Base Erosion and Profit Shifting? A Review of the Empirical Literature

11 Jan 2014

International Implications of Corporate Tax Rate Reductions

29 Mar 2013

ITPF Competitiveness Index 2013

01 Feb 2013

ITPF Competitiveness Index 2012

08 Feb 2012

The Effects Of The Taxation of Dividends on the Allocation of Foreign Portfolio Investment Around the World

01 Nov 2010

A Comparison of the Tax-motivated Income Shifting of Multinationals in Territorial and Worldwide Countries

01 Nov 2010

Where in the World Are "Permanently Reinvested" Foreign Earnings?

30 Jun 2010

Cross-Country Comparisons of Corporate Tax Systems

22 Mar 2010

The Consequences of Territorial and Worldwide Systems of International Taxation

01 Oct 2009

Investor Taxation in Open Economics

01 Aug 2009

Book-Tax Conformity: Implications for Multinational Firms

30 Mar 2009

Corporate Income Tax Burdens at Home and Abroad

30 Jan 2009

Closer Economic Integration and Corporate Tax Systems

01 Jun 2008

Expansion Abroad and the Domestic Operations of U.S. Multinational Firms

25 Sep 2003

"Taxing Multinationals," International Tax and Public Finance

01 Aug 2003

Does Acquisition by Non-U.S. Shareholders Cause U.S. Firms to Pay Less Tax

01 Jun 2003

The Effect of the Tax Reform Act of 1986 on the Location of Assets in Financial Services Firms

01 Jun 2002

Structural Estimates of Factor Substituition from Firm-Level Panel Data on Multinational Corporations

19 Feb 1999

Taxes and Cross-Border Investments: The Empirical Evidence

04 Jan 1999

What Do We Know About The Impact of Offshore Investment On The U.S. Economy

01 Jun 1996

The Compliance Cost of Taxing Foreign-Source Income: Its Magnitude, Determinants, and Policy Implications

01 Jun 1996

U.S. Interest-Allocation Rules: Effects and Policy

01 Jun 1995

Corporate Domicile and Average Effective Tax Rates: The Cases of Canada, Japan, the United Kingdom, and the United States

01 Jan 1995

Free Trade Taxation And Protectionist Taxation

01 Mar 1994

Research

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