Monday, April 27, 2015

New article draft on international tax policy, perhaps to be available soon

I have just now - and I literally mean, within the last hour - completed a draft of a shortish-by-legal-standards international tax article (just over 16,000 words), tentatively entitled "The Crossroads Versus the Seesaw: Getting a 'Fix' on Recent International Tax Policy Developments."

The basic idea is to establish a kind of cross-interrogation or dialogue between two things.  The first is the main analytical points that I made in my February 2014 book, Fixing U.S. International Taxation.  The second is four prominent developments in international tax policy since the manuscript went final. These are the new wave of U.S. inversions, the progress made since then in the OECD's BEPS project, the U.K.'s recently implemented diverted profits tax (aka "Google tax"), and the introduction of recent U.S. international tax reform proposals that could be viewed as offering suggestions regarding how to implement some of my ideas.

I find that the cross-interrogation or dialogue goes both ways.  I believe that the analysis in the book helps one to understand those developments, but also that those developments have helped me, at least, to think more clearly about some of the issues that I discuss in the book.

My immediate impetus for writing the article was to present it at the ninth annual academic symposium of the Oxford University Center for Business Taxation (at Oxford's Said Business School), which will be taking place this June 22-25.  I also hope or plan to present it at this year's National Tax Association Annual Meeting, which will be taking place in Boston on November 19-21.  And I will presumably aim eventually to publish it somewhere as well.

Forthcoming on SSRN, I suppose, but for now I will sit on it while I turn to other urgent triage items on my short-term to-do list.

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