Harnessing the costs of international tax arbitrage

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The item Harnessing the costs of international tax arbitrage represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: This article contends that the costs of international tax arbitrage can be harnessed to benefit those countries which have not historically benefited from the policies of the world tax regime - i.e. developing countries. Part II of this article summarizes the development of international arbitrage and discusses the underlying policy choices of the domestic and international tax regimes of the United States which have led to the current system. Part III then discusses responses to international tax arbitrage and analyses the criticisms of each in light of the policy choices discussed in part II. Part IV proposes a new methodology for harnessing and directing the costs of international tax arbitrage to promote worldwide development and analyses how such an approach could ultimately transform the current worldwide equilibrium into a more cooperative regime while aiding developing countries in the short term. Part V then applies this framework to a case study of a particular international tax arbitrage transaction, demonstrating the distributional and cooperative benefits of the approach proposed by this article

Work

Summary: This article contends that the costs of international tax arbitrage can be harnessed to benefit those countries which have not historically benefited from the policies of the world tax regime - i.e. developing countries. Part II of this article summarizes the development of international arbitrage and discusses the underlying policy choices of the domestic and international tax regimes of the United States which have led to the current system. Part III then discusses responses to international tax arbitrage and analyses the criticisms of each in light of the policy choices discussed in part II. Part IV proposes a new methodology for harnessing and directing the costs of international tax arbitrage to promote worldwide development and analyses how such an approach could ultimately transform the current worldwide equilibrium into a more cooperative regime while aiding developing countries in the short term. Part V then applies this framework to a case study of a particular international tax arbitrage transaction, demonstrating the distributional and cooperative benefits of the approach proposed by this article