Paul L. Caron

Saturday, October 30, 2021

Avi-Yonah: U.S. International Tax Law

Reuven Avi-Yonah (Michigan; Google Scholar):

Slicing the Shadow: A Proposal for Updating U.S. International Taxation:

This article advances a proposal for market-based formulary apportionment.

International Tax Law: Status Quo, Trends And Perspectives:

This chapter will argue that developments in the past decade have significantly bolstered the International Tax Regime, so that it does a much better job in protecting PIT and CIT from erosion due to cross-border tax evasion and avoidance than it did before 2010. Specifically, the adoption of FATCA and the consequent development of Automatic Exchange of Information (AEI) and the Common Reporting Standard (CRS) have significantly protected PIT, while the OECD BEPS project has significantly improved CIT, especially if the current BEPS 2.0 effort is successfully concluded.

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