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Forced-Labor Hearings to Spark Fresh Tariff Debate: Supply Lines (07/07/2026)

07 Jul 2026

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Brendan Murray

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Int'l Tax News
Forced-Labor Hearings to Spark Fresh Tariff Debate: Supply Lines (07/07/2026)

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Global Tax for Repair

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Notice 2026-23, 2026-2027 Priority Guidance Plan

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References to Dynamic International Standards and the Tax Legality Principle

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FTC Proposals, Part I: Creditable Foreign Taxes

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

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Potential Changes to Section 367 and the Associated Treasury Regulations

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A Global Perspective on the Incidence of Monopoly Distortions

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International Tax Reform and the Biden-Harris Tax Pledge

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Subpart F and GILTI Recommendations

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Taxation of Foreign-Derived Intangible Income

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

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

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

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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

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Mulilateral Tax Reform

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The Taxation of Robots and Its Global Challenges

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

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ICAP Documentation Requirements: Selection Documentation Package Templates

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

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

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

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The Global Minimum Tax and Special Economic Zones

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International Tax and International Law Revisited

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Can Investment Treaties Defeat Pillar 2

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Corporate Tax Statistics

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Considerations for Reforming the U.S. Transfer Pricing Rules

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Qualified Status under the Global Minimum Tax: Questions and Answers

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

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

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

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

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International Compliance Assurance Programme (ICAP) Frequently Asked Questions

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

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

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

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

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

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

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

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

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Import Competition and U.S. Sentiment Toward China

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The Design of a UN Framework Convention on International Tax Cooperation

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

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Tax Treaties and Denizenship Based Tax Systems

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

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Tax Treaties and Income Shifting

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

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

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

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Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax

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Promoting Inclusive and Effective Tax Cooperation at the United Nations

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Case Law Trend: Withholding Taxation Under the Fundamental Freedoms

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

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Tax Transparency in Africa 2024: Africa Initiative Progress Report

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

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

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Business model digitalization, competition, and tax savings

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

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Understanding the Impact of OECD BEPS Actions on Double Tax Treaties

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The Untold Tale of a Tax Rulings Haven

29 Feb 2024

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

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

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Cryptocurrency Investments and Taxation: Analyzing Global Responses by Tax Authorities

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

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

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Whither LOB?

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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

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Tax It Before Exit: Exit Taxation and Greenfield Investments

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The UTPR and the Treaties

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

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The Global Minimum Tax and the taxation of MNE profit

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Frequently Asked Questions on Pillar 2 Directive

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

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Destination Taxation of Corporate Income and the Emerging Implications

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Corporate Tax Statistics 2023

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International Tax Policy's Harm to Manufacturing and National Interests

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

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

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Global Tax Evasion Report 2024

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Profit Shifting Under the Arm’s Length Principle

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The Historical Origins and Current Prospects of the Multilateral Tax Convention

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

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Minimum Tax Implementation Handbook (Pillar Two)

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The Multilateral Convention to Implement Amount A of Pillar One

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

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

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Government Reputation, FDI, and Profit-shifting

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

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

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

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

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Globe: The Potential Costs Of Cooperation

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

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

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

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A Macroeconomic Perspective on Taxing Multinational Enterprises

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The Fundamentals of Tax Incentives

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

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The Use and Abuse of Location-Specific Rent

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Progressive Formulary Apportionment: The Case for 'Amount D'

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

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

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

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Tax Strategy Disclosure: A Greenwashing Mandate?

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

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

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

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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

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

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