OECD Pillar Two and U.S. GILTI: Comparative Analysis and Policy Implications for Multinational Tax Compliance
Download FileThis paper analyzes the interaction between OECD Pillar Two and the U.S. GILTI regime, evaluating their combined impact on multinational tax compliance and global minimum tax policy.
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The Sovereignty Paradox: Digital Services Taxes, Political Jurisprudence and the Limits of State Power in the Digital Economy
Download FileThis paper explores the tension between national tax sovereignty and global digital markets, analyzing how digital services taxes challenge traditional limits on state power.
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How the U.S. Constitution Shapes International Tax Law: Instrument Choice in Tax Agreements
Download FileThe authors explore how constitutional constraints influence the United States’ approach to international tax agreements, particularly the choice between treaties and executive agreements.
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Digital Services Taxes and the WTO
Download FileThis paper examines whether digital services taxes comply with WTO obligations and analyzes their role in the broader landscape of international tax coordination.
Citation: Avi-Yonah, Reuven S. and Narotzki, Doron, Digital Services Taxes and the WTO (March 14, 2026). U of Michigan Law & Econ Research Paper Forthcoming, 121 Tax Notes Int’l 1223 (2026)
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International Tax Reform and Multinational Corporate Behavior: Conceptual Insights from the One Big Beautiful Bill Act
Download FileThe paper explores how recent international tax reforms could influence the behavior of multinational corporations, focusing on incentives related to profit shifting, investment location, and tax competition.
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Fiscal Limits to Protectionism: The 2025 U.S. Tariff Laffer Curve
Download FileThis paper examines whether increasing tariffs can eventually reduce government revenue by shrinking trade flows, applying the concept of a Laffer Curve to recent U.S. tariff policy and global trade dynamics.
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Hidden Profits, Lost Jobs? Tax Havens and Employment Decisions
Download FileThe study examines how multinational firms’ use of tax havens affects employment decisions, exploring whether profit shifting alters job creation and investment patterns across countries.
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What is the Share of U.S. Tariffs Paid by Exporters?
Download FileThis paper investigates how the burden of U.S. tariffs is distributed between foreign exporters and domestic consumers, providing new evidence on tariff incidence in global trade.
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The “Hidden Sides” of the Taxation of Dividends and Interest for Corporate America versus Corporate Europe
Download FileThis paper compares how dividend and interest taxation differs between the United States and Europe, highlighting structural differences in corporate tax systems and their implications for multinational firms.
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Tariffs and Firm Expectations
Download FileThis paper examines how tariff policies influence firms’ expectations about investment, production, and economic conditions, highlighting how trade policy uncertainty affects corporate decision-making.
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