Stateless income

ED Kleinbard - Fla. Tax Rev., 2011 - HeinOnline
This paper and its companion, The Lessons of Stateless Income, together comprehensively
analyze the tax consequences and policy implications of the phenomenon of" stateless …

The lessons of stateless income

ED Kleinbard - Tax L. Rev., 2011 - HeinOnline
This Article continues the analysis begun in a companion paper, Stateless Income.'That prior
analysis defined" stateless income" as" income derived by a multinational group from …

Rethinking limited liability of parent corporations for foreign subsidiaries' violations of international human rights law

G Skinner - Wash. & Lee L. Rev., 2015 - HeinOnline
The doctrine of limited liability of shareholders often prevents victims harmed by a
corporation's foreign subsidiary's violation of international human rights norms from …

Indeterminacy, complexity, technocracy and the reform of international corporate taxation

S Picciotto - Social & Legal Studies, 2015 - journals.sagepub.com
Recent public concerns and publicity about the extent of tax avoidance by some of the
largest and most respected transnational corporations have prompted numerous …

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 …

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

D Dharmapala - International Tax and Public Finance, 2024 - Springer
The 2017 US tax legislation—widely referred to as the Tax Cut and Jobs Act (TCJA)—
fundamentally transformed the US system of international taxation. It ostensibly ended …

Why are there tax havens

AH Rosenzweig - Wm. & Mary L. Rev., 2010 - HeinOnline
Recently, the issue of tax havens has risen to the fore of the fiscal policy debate, with tax
havens being singled out as the root cause of many of the fiscal shortfalls plaguing the …

Can Tax Expenditure Analysis Be Divorced from a Normative Tax Base?: A Critique of the" New Paradigm" and Its Denouement

JC Fleming Jr, RJ Peroni - Va. Tax Rev., 2010 - HeinOnline
In spite of the controversy that surrounds it, tax expenditure analysis (TEA), at its core, is a
simple, intuitively obvious idea. For example, assume that recently independent hypothetical …

Revisiting global formulary apportionment

SC Morse - Va. Tax Rev., 2009 - HeinOnline
A formidable tangle of international tax rules currently divides global jurisdiction to tax.
Would formulary apportionment fix it? One proposal advocates the global allocation of …