Monday, April 20, 2020
Ruth Mason (Virginia), The Transformation of International Tax, 114 Am. J. Int'l L. ___ (2020):
The recession of 2008 precipitated a political crisis that motivated an unprecedented international project to curb corporate tax dodging. This Article argues, contrary to dominant scholarly views, that this effort transformed international tax — changing its participants, agenda and institutions, norms, and even its legal forms. Perhaps most important, efforts to close corporate tax loopholes opened a rift over the resulting revenues that threatens a hundred-year-old tax treaty framework.
This Article identifies and critically evaluates these changes from the perspectives of revenue, inclusivity, legitimacy and accountability, innovation, and durability.