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Rethinking the Source of the Arm's-Length Transfer Pricing Problem
Almost everyone agrees that the arm’s-length standard is inapt for sourcing a multinational enterprise’s (MNE) income. At the same time, all consider it unlikely that tax authorities will explicitlyExpand
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How to redistribute?: A critical examination of mechanisms to promote global wealth redistribution
The literature on global redistributive justice deals primarily with the important, yet unresolved issues of why global wealth redistribution may be morally justified or beneficial. However,Expand
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The Quest to Tax Financial Income in a Global Economy: Emerging to an Allocation Phase
The taxation of the income derived from financial assets and transactions was always a daunting black hole in the income tax regime. In an integrated global market, tax authorities find it hard toExpand
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How to Live with a Tax Code with Which You Disagree: Doctrine, Optimal Tax, Common Sense, and the Debt-Equity Distinction
The current financial crisis and recession demonstrate the overwhelming social cost of high leverage. While many factors contributed to the development of the crisis, one factor is frequentlyExpand
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Sourcing the 'Unsourcable': The Cost Sharing Regulations and the Sourcing of Affiliated Intangible-Related Transactions
The article examines the current U.S. cost sharing regulations (hereinafter, the CSRs) along with the still-pending and highly controversial proposed CSRs (published August 05). After presenting theExpand
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Corporate Political Agency
This Essay explains why the investor-shareholder relationship gives rise to political agency problems that neither the Law and Economics nor the critical Corporate Social Responsibility literatureExpand
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Formulary Apportionment: Myths and Prospects - Promoting Better International Tax Policy and Utilizing the Misunderstood and Under-Theorized Formulary Alternative
This paper seeks to re-examine the formulary alternative to transfer pricing by inquiring whether partial integration of formulary concepts into current practices would offer a reasonable alternativeExpand
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A common perception among international relations policymakers and theorists is that states’ primarily self-serving motivations inhibit their participation in promoting internationalExpand